Updated WA Biomass Response to Submissions FINAL 21 May …€¦ · Title: Updated WA Biomass_Response to Submissions FINAL 21 May 2008 Author: graslr Subject: Manjimup Biomass Power

Response to Submissions Proposed Biomass Power Plant, Manjimup WA Biomass Pty Ltd 21 May 2008 Reference 25642

Connell Wagner Pty Ltd ABN 54 005 139 873 Level 1, Septimus Roe Square 256 Adelaide Terrace Perth Western Australia 6000 Australia Telephone: +61 8 9223 1500 Facsimile: +61 8 9223 1605 Email: [email protected] www.conwag.com

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Document ID: P:\25642\6.0 REPORTS_SPECS\DIAMOND MILL\PER\EPA SUBMISSIONS TO PER\OUTGOING\UPDATED WA BIOMASS_RESPONSE TO SUBMISSIONS FINAL 21 MAY 2008.DOC

Rev No Date Revision Details Typist Author Verifier Approver

0 21 May 2008 Response to Submissions REH Various NM JB

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Proposed Biomass Power Plant, Manjimup WA Biomass Pty Ltd Response to Submissions

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Contents Section Page

1. Introduction 1 1.1 Purpose of this Document 1 1.2 Structure of this Document 1 1.3 Background 2 1.4 Issues and Statements Raised in Submissions 9

2. Submissions to the PER 10

3. Revised Project Documentation 12 3.1 Revised Project Description 13 3.2 Revised Project Management 14 3.2.1 Fuel Supply 14 3.2.2 Visual Management 15 3.2.3 Soil Erosion and Sediment Management 17 3.2.4 Greenhouse Gas Emissions Management 19 3.2.5 Water Quality Management 21 3.2.6 Vegetation & Habitat Management 24 3.2.7 Heritage & Cultural Management 27 3.2.8 Air Quality Management 29 3.2.9 Noise Management 34 3.2.10 Waste Management 36 3.2.11 Hazard and Risk Management 40 3.2.12 Fire Management 43 3.2.13 Social and Economic Impact Management 45 3.2.14 Traffic and Transport Management 47

4. Response to Submissions 49 4.1 Fuel Supply 49 4.2 Land Use and Soils 56 4.3 Visual Impact 63 4.4 Greenhouse Gas Emissions 65 4.5 Air Quality 69 4.6 Noise Quality 87 4.7 Surface and Groundwater 88 4.8 Flora and Fauna 95 4.9 Indigenous and Non-Indigenous Cultural Heritage 100 4.10 Solid and Liquid Waste 102 4.11 Hazard and Risk 104 4.12 Social and Economic 104 4.13 Transport 107 4.14 Health Risk 110 4.15 Monitoring and Management 112 4.16 Miscellaneous 116

5. Stakeholder Consultation Summary 121


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List of Figures Figure 1-1: State Context Plan ............................................................................................................. 3 Figure 1-2: District Location Plan........................................................................................................ 4 Figure 1-3: Site Location Plan.............................................................................................................. 4 Figure 1-4: Site Context........................................................................................................................ 5 Figure 1-5: Site Zoning Plan, Shire of Manjimup TPS No.2............................................................... 6 Figure 1-6: Site Layout Plan................................................................................................................. 8

List of Tables Table 3-1 Key Project Characteristics............................................................................................... 13 Table 3-2 Revised Management Actions........................................................................................... 15 Table 4-1 Fuel Supply Issues & Statements .................................................................................... 51 Table 4-2 Land Use and Soils Issues & Statements ....................................................................... 58 Table 4-3 Visual Issues & Statements.............................................................................................. 65 Table 4-4 Greenhouse Gas Emissions Issues & Statements......................................................... 66 Table 4.5 Annual emissions of particulates for comparison of prescribed burning to biomass

power station combustion......................................................................................................... 71 Table 4-6 Air Quality Issues & Statements ...................................................................................... 72 Table 4-7 Noise Quality Issues & Statements ................................................................................. 87 Table 4-8 Surface and Groundwater Issues & Statements............................................................. 89 Table 4-9 Flora and Fauna Issues & Statements............................................................................. 95 Table 4-10 Cultural Heritage Issues & Statements........................................................................ 100 Table 4-11 Solid and Liquid Waste Issues & Statements ............................................................. 102 Table 4-12 Social and Economic Issues & Statements ................................................................ 104 Table 4-13 Transport Issues & Statements.................................................................................... 107 Table 4-14 Health Risk Issues & Statements................................................................................. 111 Table 4-15 Monitoring and Management Issues & Statements.................................................... 113 Table 4-16 Miscellaneous Issues & Statements............................................................................ 116


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Appendices Appendix A

Report on Forestry Aspects of the Synergy Displacement Tender (Fifth Estate, March 2008) Appendix B

Correspondence from biomass fuel suppliers (WA Plantation Resources, 11 March 2008; Forest Products Commission, 14 March 2008; Great Southern Limited, 18 March 2008 Integrated Tree Cropping, 27 March 2008)

Appendix C Review of data relating to potential pollution of soil and effects on plants around a proposed biomass power plant at Manjimup, Western Australia (Prof. M.J. McLaughlin, Centre for Environmental Contaminants Research, CSIRO Land and Water, 10 April 2008).

Appendix D

Report on the Possibility of Air Pollution from a Biomass Power Station affecting neighbouring Vineywards and Wineries (Dr Richard E Smart, Smart Viticulture, 18 April 2008)

Appendix E

(a) Air Quality Assessment, Biomass Power Station, Manjimup (Connell Wagner, April 2008)

(b) Correspondence from Katestone Environmental (Simon Welchman, 18 April 2008) Appendix F

Noise contours Appendix G

(a) Stormwater Modelling and Proposed Management Options (Queensland Laboratory, Occupational Hygiene & Environmental Consultants, April 2008)

(b) Correspondence from the Department of Water (Water Source Protection Branch, 18 April 2008)

Appendix H

(a) Preliminary health risk assessment of air emissions from proposed Biomass Power Station, Manjimup (Dr Roger Drew, Toxikos Pty Ltd, 11 April 2008)

(b) Correspondence from the Department of Health (Environmental Health Directorate, 11 April 2008)


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1. Introduction

1.1 Purpose of this Document

The purpose of this document is to provide responses to the issues raised in submissions made on the Public Environmental Review (PER) prepared for the proposed Biomass Power Plant, Palings Road, Diamond Tree, Manjimup by Western Australia Biomass Pty Ltd (WA Biomass). The Environmental Impact Assessment (Part IV Division 1) Administrative Procedures 2002 state that the Proponent is required to prepare a summary of the pertinent issues raised in public and government agency submissions.

1.2 Structure of this Document

The structure of this Response to Submissions document is presented as follows: Section 1 Introduction to the document and proposal details. Section 2 Outlines the number and source of submissions that were received. Section 3 Presents revised project documentation, based on the outcome of amendments made as a result of further assessments / research and in response to the public submissions to the PER. This includes revised environmental management plans and actions. Section 4 Provides individual responses to the issues raised in submissions. The Appendices also provide additional information in response to submissions raised. Section 5 Presents the outcomes of the extensive community consultation work undertaken in addition to the advertising and comment on the PER document. Each issue raised in the submissions is presented in table format with a response provided adjacent to the issue. In numerous cases submissions were received on the same topic/issue. Where the identity of the submitter is known, this information is provided, to enable authors of the submissions to identify responses to their comments. The identities of authors from members of the public are not shown. Submissions have been identified in the document by the numerical value provided to the proponent by the EPA. It is strongly recommended that submitters read the entire Section relating to their point, comment or question, as other relevant answers may be contained within. Additional assessment and investigation has been undertaken in response to submissions are the findings of this additional work are provided as appendices. These include: Appendix A: A Report on Forestry Aspects of the Synergy Displacement Tender (Fifth Estate, March 2008) involved a review of the proposed fuel supply, including:

• The availability and sustainability of the required quantity of wood and forest based fuel, • The proposed purchase contracts under which the wood and forest based fuels will be procured, • The suppliers; capacity to meet the quantity and quality of wood and forest based fuels specified in

the purchase contracts, • The capacity of the fuel suppliers and/or the proponent to, where relevant, harvest, gather, collect

and transport the wood and forest based fuels, • The reasonableness and sustainability of the costing associated with the procurement, harvesting,

gathering, collecting and transporting of the wood and forest based fuels, • Any other risks associated with the supply of wood and forest based fuel.


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Appendix B: Correspondence from the four major fuel supply contractors regarding their plantation management regimes and current practices, including burning of plantation waste. Appendix C: An assessment by CSIRO Land and Water of the data relating to potential pollution of soil and effects on plants around the proposed biomass power plant. This involved a review of several sources of contaminants and data for the atmospheric emissions from the proposed biomass power plant, namely particulates, nitrogen and sulfur oxides, persistent organic compounds, and (non-organic) trace elements (inorganic contaminants). Hazard quotients (HQs) were predicted for contaminants accumulating in soil over the life of the plant, using predicted environmental concentrations (PECs) and predicted no-effect concentrations (PNECs) derived from regulatory benchmarks. Appendix D: A report by Smart Viticulture which assesses the potential impacts of plant emissions on grapes and viticulture in the area of the proposed biomass power plant. Appendix E(a): The revised Air Quality Report for the proposed Biomass Plant which addresses the issues raised in the Katestone peer review and the report by SKM, commissioned by the Shire of Manjimup, as well as responding to submissions from the community on the PER. Appendix E(b): Correspondence from Katestone Environmental who conducted a peer review of the air quality impact assessment study that was prepared by Connell Wagner. Appendix F: Revised noise contours, reflecting the location of the fuel storage site. Appendix G: The Stormwater Modelling and Proposed Management Options for the proposed site. This report presents a response to the Department of Water comments on the PER regarding the stormwater modelling and management for the proposed Biomass Power Station. Appendix G(b): comprises the Department of Water’s comments on review of the stormwater modelling and proposed management options. Appendix H(a): Preliminary Health Risk Assessment undertaken by Dr Roger Drew of Toxikos to examine the potential impacts on human health from the biomass power plant. The HRA has been conducted according to national and international guidelines and included an assessment of acute and chronic health risks that might arise from direct inhalation exposure to individual components of the emissions and the mixture of chemicals in the emissions. Also incorporated into the HRA is a quantitative evaluation of cancer risks, and a preliminary evaluation of the potential health risks associated with exposure of emission components through the food chain (i.e. indirect exposure pathways). Appendix H(b): comprises the Department of Health’s comments on review of the Preliminary Health Risk Assessment undertaken by Dr Roger Drew of Toxikos.

1.3 Background

WA Biomass proposes to develop a Biomass Power Plant south of Manjimup in the South West of Western Australia, approximately 300km south of Perth and 85km south of Bunbury (see Figure 1.1). The proposed facility will comprise a 40 MW (nominal) biomass fuelled power plant, to be located approximately 10km south of Manjimup (see Figure 1.2 and Figure 1.3). The proposed Power Plant facility comprises a conventional steam cycle plant generating approx 322GWh (net) / annum of electrical power which will be supplied to the South West Interconnected System (SWIS). The proposed site is part of Forest Lease No.1994/97 currently used for the WA Plantation Resources (WAPRES) Diamond Timber Mill. Access to the site would be along Eastbourne Road, off the South Western Highway, utilizing the same access route as the Timber Mill. The site is currently reserved for “State Forest” under the Shire of Manjimup Town Planning Scheme No.2 (see Figure 1.4).


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The land surrounding the site is reserved for State Forest, providing a good forest buffer to surrounding rural land uses. Residences in this rural area are quite disparate, with the nearest dwelling being approx 1.4km to the north of the proposed development area (see Figure 1.5).

Figure 1-1: State Context Plan


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Figure 1-2: District Location Plan

Figure 1-3: Site Location Plan


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Figure 1-4: Site Context


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Figure 1-5: Site Zoning Plan, Shire of Manjimup TPS No.2


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The power station will be a conventional steam cycle plant generating electrical power which will be supplied to the South West Interconnected System (SWIS). The power plant will comprise the following main facilities: • Fluidised bed boiler using forestry wastes as fuel; • Baghouse filter; • Condensing steam turbo generator; • Air cooled condensing plant; • Water treatment and boiler feed water system; • Ash wetting and disposal system; • Waste water system; • Fuel storage, handling and supply system; • Electrical grid connection facility including step up transformer and plant auxiliaries; and • Car park and control room. The plant equipment and associated systems will be contained within the existing lease area. The proposed site has been logged and/or cleared and has been recently used as a transport depot. It is directly adjacent to the WA Plantation Resources Diamond Timber Mill woodchipping operations. Approximately 380,000 tonnes/annum of plantation waste will be purchased from independent contractors, who will collect, process and deliver the biomass fuel to the Plant. The volumes to be supplied are to be drawn from plantations within a maximum radius of 100km and transported by road from the source to the Power Plant. At present the timber is stockpiled and burnt in the fields where the trees are harvested, resulting in local pollution and the release of greenhouse gases. By burning the timber in an electricity generator, the plant offsets production of electricity from fossil fuels and therefore abates greenhouse emissions. Figure 1.6 indicates the general Site Layout


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1.4 Issues and Statements Raised in Submissions

Sixty-seven individual submissions were received by the Environmental Protection Agency (EPA) regarding the proposed development of a Biomass Power Plant at Diamond Mill, Manjimup. Of the submissions received, 33 supported the development of the Biomass Plant in Manjimup while 22 opposed it. Other submissions offered comments and recommendations for development. Five group submissions were also received, all but one of these in support of the proposal. The submission from the Shire of Manjimup contained the comments received by the Shire during advertising of the Development Application (thereby encapsulating 510 submissions), as well as a copy of the independent review on Air Quality conducted by Sinclair Knight Mertz at the request of the Shire. The primary reasons for support of the development of a Biomass Power Plant at Diamond Mill, Manjimup were:

• Increase in the use of renewable energy, contributing to the State meeting its renewable energy targets;

• Efficient utilisation of a resource that is currently being wasted; • Improvement to local air quality and reduction in the occurrence of uncontrolled burning in the area. • Reduction in Greenhouse Gas Emissions; • Improvement in Forest Management Practices. • The proposed site is suitable as its is already an industrial area, it is close to a power substation, there

is existing infrastructure on site with existing suitable buffers in place and there will be minimal impact on local water sources;

• An efficient road transport network is already in place to service the proposal; • Creation of jobs and skills for the Manjimup area, thereby leading onto additional economic benefits

and attraction of new industry to the area; and • Improvement in the reliability of power in the district.

Various reasons were provided outlining details as to why development of the Biomass Power Plant should not be approved at Diamond Mill, Manjimup. The primary reasons provided were due to:

• Potential air quality impacts on health and agriculture (particularly local wineries and food crops); • Water quality (including impact on rainwater /drinking water systems, and irrigation supplies); • Sustainability of the plantation waste supply and potential impact on plantation management practices; • Safety and road maintenance issues associated with additional heavy haulage on the roads; • Affect on local amenity and perceived impact on tourism and property values.

In addition, various comments were received primarily from Local and State organisations providing recommendations for development and highlighting particular criteria that will need to be addressed. The issues raised, and the recommendations and comments provided are further discussed in Section 4.


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2. Submissions to the PER

The list of submitters is provided in the table below. Each issue raised in the submissions is presented in table format in Section 4, with a response provided adjacent to the issue. In numerous cases submissions were received on the same topic/issue. Where the identity of the submitter is known, this information is provided, to enable authors of the submissions to identify responses to their comments. The identities of authors from members of the public are not shown. Submissions have been identified in the document by the numerical value provided to the proponent by the EPA. It is strongly recommended that submitters read the entire Section relating to their point, comment or question, as other relevant answers may be contained within.

Table 2-1 List of Submissions

Submission Number Submitter

1 Private 2 Private 3 Private 4 Private 5 Private 6 Private 7 Private 8 Small Business Centre 9 Private 10 Private 11 Private 12 Private 13 Wine Industry of Western Australia 14 Food Industry Association WA Inc 15 Main Roads South West Region 16 Private 17 Private 18 Manjimup Chamber of Commerce & Industry (Inc.) 19 Private 20 The Bushfire Front Inc 21 Manjimup Tourist Bureau Inc. T/A the Manjimup Visitor Centre 22 Telethon Institute for Child Health Research 23 Tourism Western Australia 24 Private 25 Member for Warren Blackwood 26 Member for South West Region 27 Private 28 Private 29 Pemberton Visitor Centre Inc 30 Pemberton Wine Region Association 31 Private 32 Private 33 Private 34 Timber Communities Australia (WA State Office) 35 Private 36 Private 37 Private 38 Private 39 Private


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40 Private 41 Picardy Wines 42 Member for Alfred Cove 43 Western Australian Sustainable Energy Association 44 Warren Water Management Area Advisory Committee 45 Department of Indigenous Affairs 46 Department of Health 47 Private 48 Private 49 Timber Communities Australia (Warren Branch) (18 signatures) 50 Private 51 Department of Environment and Conservation 52 Environment Protection Agency 53 Shire of Manjimup (510 submissions) 54 Conservation Council of Western Australia Inc 55 Manjimup Biomass Proposal Support Group (20 signatures) 56 Private 57 Private 58 Private 59 Private 60 Private 61 Private 62 Private 63 Department of Water 64 South-West Forests Defence Foundations Inc. 65 Western Australian Forest Alliance 66 The Wilderness Society WA 67 Heritage Council of WA

Group Submission 1 Private (32 signatures) Group Submission 2 Private (33 signatures) Group Submission 3 Private (45 signatures) Group Submission 4 Private (32 signatures) Group Submission 5 Private (68 questionnaires)


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3. Revised Project Documentation

In response to government, non government organisations and community submissions to the PER, as well as through feedback to extensive community consultation, and independent peer reviews, additional third party studies have been undertaken. The key additional study consists of a revised Air Quality Assessment by Connell Wagner. The following conclusions are made by assessment of the air quality model results with the relevant criteria:

• Sulphur Dioxide: Predicted concentrations are an order of magnitude below air quality standards. • Nitrogen Dioxide: Extreme worst case scenario prediction methods show that NO2 concentrations

comply with the relevant air quality standards, whereas more realistic simulation of both emissions from the proposed facility and background sources shows that predicted levels are well below the air quality standards.

• Coarse Particulates (PM10): Ground level concentrations from the power station alone are shown to be an order of magnitude below the air quality standards. Cumulative concentrations primarily result from background concentrations in the Manjimup/Bridgetown region, and are significantly below the relevant air quality standards.

• Fine Particulates (PM2.5): Ground level concentrations from the power station alone are shown to be an order of magnitude below the air quality standards. Cumulative concentrations primarily result from background concentrations in the Manjimup/Bridgetown region. The daily averaged cumulative concentrations comply with the air quality standards while annually averaged background concentrations exceed the air quality standards (with negligible affect of concentrations due to the biomass power station).

• Carbon Monoxide and Lead: Predicted concentrations are several orders of magnitude below air quality standards.

• Persistent Organic Pollutants, Volatile Organic Compounds and Trace Elements: Predicted ground level concentrations of all compounds are well below air quality standards.

The predicted concentrations of pollutants in air were used to conduct separate expert independent human health, horticultural and viticultural risk assessments. The main conclusions from these separate studies were:

• Health Risk Assessment: It is extremely unlikely that emissions from the power plant will result in adverse effects on human health.

• Horticultural Risk Assessment: Risk of pollutant concentrations in the air on horticulture in the region from deposition of trace elements and gaseous compounds varies from being acceptable to negligible.

• Viticultural Risk Assessment: Risk of smoke taint of grapes and wine from the emissions of bound organic compounds from the Biomass Power Plant are considered to be negligible.

Mitigation and management measures have been recommended through these studies. Where the responses have warranted a revision to project documentation, the amendment has been detailed within this section.


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3.1 Revised Project Description

Major project characteristics remain the same. Where changes have been made, these have been highlighted in bold.

Table 3-1 Key Project Characteristics

Element Details

Project purpose To construct a 40 MW Biomass fuelled Power Plant facility that will comprise a conventional steam cycle plant generating 322GWh (net) / annum of electrical power, which will be supplied to the South West Interconnected System (SWIS).

Life of project 25 years

Generation capacity 40 MWe (nominal)

Thermal capacity 175MWth (nominal)

NB: These figures are noted as ‘nominal’ as these capacities vary to a minor extent (+/- 1%) depending on the ambient conditions.

Electrical output Approximately 322GWh (net) / annum

Facility footprint Approximately 5 hectares

Fuel:

Type Plantation waste – Eucalyptus Globulus (Bluegum) and Pinus Radiata (Pine)

Volume per annum Approximately 380,000 tonnes

Transportation Road (B-Double truck & trailer)

Plant facilities:

Boiler Bubbling fluidised bed

Emissions Control Technology Sophisticated control system for the combustion system within the boiler, together with fabric filters within a baghouse.

Steam Turbine Axial exhaust condensing steam turbine

Generator Synchronous generator equipped with closed circuit water to air cooling system

Dry cooling system Direct air cooled condenser comprises of a required number of bays

Stack height 40 metres

Reverse Osmosis / Electrodionisation (EDI) Plant

Raw water supplied for treatment and used as boiler feed water

Plant availability Availability factor 92%

Inputs:

Plantation waste Approximately 380,000 tonnes per annum

Raw water Approximately 24 ML per annum

Outputs:

Ash A maximum 5% of total Biomass fuel processed

Boiler blow down water Approximately 0.93 m³ per hour

Sewage Approximately 401,500 Litres per annum

Proposed Biomass Power Plant, Manjimup WA Biomass Pty Ltd

Response to Submissions

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Element Details

Air Emissions Emissions Guarantees at 100% Maximum Continuous Rating

(MCR) when firing design fuel

Particulate emissions 30mg/Nm3 of dry gas at 0C, 101.3kPa and 6% O2 conditions

NO2 300mg/Nm3 of dry gas at 0C, 101.3kPa and 6% O2 conditions

CO 200mg/Nm3 of dry gas at 0C, 101.3kPa and 6% O2 conditions

SO2 78mg/Nm3 of dry gas at 0C, 101.3kPa and 6% O2 conditions

Operational Noise Emissions The predicted maximum noise level at the closest receiver is 33 dBA

3.2 Revised Project Management

As a result of community consultation, submissions received and the additional assessment undertaken,

amendments to the environmental management plans have been made. The environmental management

actions stated in the PER and summarised in Section 22 of the PER document are amended as follows.

3.2.1 Fuel Supply

A Fuel Supply Management plan is proposed, to include:

The biomass power plant will only use plantation timber waste that is eligible under the Australian

Government Office of the Renewable Energy Regulator wood waste eligibility criteria.

Samples of fuel will be tested to ensure the correct fuel mix is maintained, and that the fuel does not

include treated waste material (eg. Insecticides or other synthetic composites). Testing will be carried out

on a monthly basis over the first year of operation, and thereafter 3 monthly for the life of the plant.

Fuel analysis will be undertaken in an accredited laboratory to ensure the fuel specification is met for

optimum operation and efficiency of the plant.

In accordance with fuel supply contract requirements, the proponents and its contractors will ensure that

plantations are managed in accordance with relevant compliance systems, standards and codes of

practice including:

The suppliers Environmental Management System

Code of Practice for Timber Plantations in WA

Timber Harvesting Manual (Plantations)

Standards of Practice as published by the Forest Stewardship Council of Australian Forestry

Standards

The regimes required of the above systems and standards will ensure minimum impacts from the plantations on

the surrounding environment.

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Table 3-2 Revised Management Actions

3.2.2 Visual Management

Management Action in the PER Amended and Additional Management Actions

Construction

• As part of site induction and environmental awareness training, all construction staff will be informed of the environmental issues associated to the site and their obligations relating to construction activities.

• Maintain the existing State Forest barrier to create a visual buffer for the Plant and chimney stack.

• Revegetate the area between the site and Palings Rd to strengthen the existing buffer. • Paint the chimney stack a suitable low reflective colour (pale grey) which limits visibility of the

stack. • Paint external buildings and plant equipment “mist green” to suit site surrounds Operation

• Maintain visual buffer around the plant • Maintain building surfaces and non-reflective coatings where relevant. • Ensure site grounds and yards are maintained in a clean and tidy manner. Monitoring & Reporting

• Maintain record for induction attendance. • Visual inspection. • Regular inspections on the vegetation growth Corrective Action Re-paint where required. Re-vegetate cleared areas (where this meets other operative objectives).

Construction


• Maintain the existing State Forest barrier to create a visual buffer for the Plant and chimney stack.

• Revegetate the area between the site and Palings Rd to strengthen the existing buffer.

• Paint the chimney stack a suitable low reflective colour (pale grey) which limits visibility of the stack.

• Paint external buildings and plant equipment “mist green” to suit site surrounds

Operation

• Maintain visual buffer around the plant • Maintain building surfaces and non-reflective coatings where relevant. • Ensure site grounds and yards are maintained in a clean and tidy

manner. Monitoring & Reporting

• Maintain record for induction attendance. • Visual inspection. • Regular inspections on the vegetation growth Corrective Action Re-paint where required. Re-vegetate cleared areas (where this meets other operative objectives). Amended and Additional Management Actions :


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Maintain the existing vegetation barrier within the lease area to create a visual buffer for the Plant and chimney stack. The proponent commits to preparing a detailed landscaping plan based on consultation with the DEC's Warren Region, to demonstrate requirements for additional screening to address local visual impact in the potential case that the surrounding State forest is logged resulting in impacts on local visual amenity. This plan will be provided to the Shire Council with the detailed design of the proposal.


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3.2.3 Soil Erosion and Sediment Management


Construction


• Erosion and sediment control measures will be provided prior to earthworks commencing and during construction as outlined in WA publication for Soil Erosion and Sediment Control.

• Control of erosion and sediment on site will follow the erosion and sediment control plan submitted as part of the approved Operational Works application.

• Top -soil stockpiles will be stabilised to prevent erosion • A detailed geotechnical assessment for engineering purposes to be undertaken prior

to construction. • Limit traffic movement on exposed soils.

Operation

• Ensure erosion is minimised across the site. Monitoring & Reporting

• Maintain record for induction attendance. • Visual inspection of all temporary and permanent sediment and erosion control

devices on a weekly basis and after any moderate rainfall events. • Weekly inspections of all working areas for signs of erosion. • Visual inspection stock piles. • Regular inspections on the vegetation growth • Re-vegetated where cleared. • Regular inspection of drainage system.

Corrective Action

• Clean out or repair sediment and erosion control devices to maintain a minimum 70% device capacity prior to construction continuing.

• Stabilise stockpiles. • Wetting of soils to control dust.

Construction


• Erosion and sediment control measures will be provided prior to earthworks commencing and during construction as outlined in WA publication for Soil Erosion and Sediment Control.

• Control of erosion and sediment on site will follow the erosion and sediment control plan submitted as part of the approved Operational Works application.

• Top -soil stockpiles will be stabilised to prevent erosion • A detailed geotechnical assessment for engineering

purposes to be undertaken prior to construction. • Limit traffic movement on exposed soils.

Operation

• Ensure erosion is minimised across the site. Monitoring & Reporting

• Maintain record for induction attendance. • Visual inspection of all temporary and permanent sediment

and erosion control devices on a weekly basis and after any moderate rainfall events.

• Weekly inspections of all working areas for signs of erosion. • Visual inspection stock piles. • Regular inspections on the vegetation growth • Re-vegetated where cleared. • Regular inspection of drainage system.

Corrective Action

• Clean out or repair sediment and erosion control devices to maintain a minimum 70% device capacity prior to


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construction continuing. • Stabilise stockpiles. • Wetting of soils to control dust.


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3.2.4 Greenhouse Gas Emissions Management


Construction


• Minimise where possible, the use of earthmoving activities, construction activities and vehicle movements.

• Construction period is maintained within the allocated timeframe. Operation

• Optimise energy generation to minimise losses, maximise output and ensure viable operation.

• Optimise plant efficiency (fuel handling, combustion efficiency and auxiliary energy) • Incorporate energy saving concepts into detailed design. • Minimise fuel transport distances as far as practicable. • Sustainably managed plantations will be used for biomass fuel supply. • Handling of sewage effluent will be designed to avoid or minimise methane emissions • Minimise the use of distillate for start-up and combustion stability.

Monitoring & Reporting

• Maintain record for induction attendance. • Weekly construction meetings to be held to review timeframe, project milestones and

record progress. • Record plant equipment efficiency and operations on a daily basis. • Record volume of supplementary fuel (distillate), steam and water used. • Monitor and record energy saving. • Record the number of truck movements per day. • Record biomass fuel supply (including volumes & composition).

Corrective Action

• Re evaluate plant performance • Identify areas for improvement within the plant and operational systems. • Review truck movements.

Construction


• Minimise where possible, the use of earthmoving activities, construction activities and vehicle movements.

• Construction period is maintained within the allocated timeframe.

Operation

• Optimise energy generation to minimise losses, maximise output and ensure viable operation.

• Optimise plant efficiency (fuel handling, combustion efficiency and auxiliary energy)

• Incorporate energy saving concepts into detailed design. • Minimise fuel transport distances as far as practicable. • Sustainably managed plantations will be used for biomass

fuel supply. • Handling of sewage effluent will be designed to avoid or

minimise methane emissions • Minimise the use of distillate for start-up and combustion

stability. Monitoring & Reporting

• Maintain record for induction attendance. • Weekly construction meetings to be held to review

timeframe, project milestones and record progress. • Record plant equipment efficiency and operations on a daily

basis. • Record volume of supplementary fuel (distillate), steam and

water used. • Monitor and record energy saving. • Record the number of truck movements per day.


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• Record biomass fuel supply (including volumes & composition).

Corrective Action

• Re evaluate plant performance • Identify areas for improvement within the plant and

operational systems. • Review truck movements.


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3.2.5 Water Quality Management


Construction


• Implement soil, erosion and sediment controls as prescribed in Section 22.4.2. • Stormwater generated on-site to be collected and treated in a stormwater pond.

Operation

• Zero process water discharge to the environment during operation. • Low risk stormwater run-off to be collected and treated in stormwater pond. • Stormwater run-off from hydrocarbon storage areas to be collected in an oil/water

separator with treated effluent then discharged to stormwater pond. • Process wastewater to be utilised in the ash wetting process and not discharged off-

site. • Hydrocarbon storage areas to be bunded. • For hydrocarbons, storage and handling will be conducted in accordance with

Australian Standards for Storage and Handling of Flammable and Combustible Liquids (AS1940) and other relevant Australian Standards.

• Stormwater pond will be designed, maintained and monitored to mitigate against mosquito populations.


• Report spills and contamination events to Project Principal and or Site Supervisor. • Regular performance and water quality monitoring of stormwater pond. • Regular inspection and monitoring of the septage treatment and disposal unit to be

undertaken. • Regular inspection of the bunded facilities. • Regular inspection of mosquito mitigation measures. • All Monitoring results are to be available to DEC. • If there was any increase in pollutant levels due to the operation of the power plant,

the proponents will review the plant filtration and control processes accordingly. Corrective Action

• Notify DEC where monitoring results exceed trigger values set out in contingency

Construction


• Implement soil, erosion and sediment controls as prescribed in Section 22.4.2.

• Stormwater generated on-site to be collected and treated in a stormwater pond.

Operation

• Zero process water discharge to the environment during operation.

• Low risk stormwater run-off to be collected and treated in stormwater pond.

• Process wastewater to be utilised in the ash wetting process and not discharged off-site.

• Hydrocarbon storage areas to be bunded. • For hydrocarbons, storage and handling will be conducted in

accordance with Australian Standards for Storage and Handling of Flammable and Combustible Liquids (AS1940) and other relevant Australian Standards.

• Stormwater pond will be designed, maintained and monitored to mitigate against mosquito populations.


• Report spills and contamination events to Project Principal and or Site Supervisor.

• Regular performance and water quality monitoring of stormwater pond.

• Regular inspection and monitoring of the septage treatment and disposal unit to be undertaken.

• Regular inspection of the bunded facilities. • Regular inspection of mosquito mitigation measures.


PAGE 22

plan • Implement contingency plan where pollutant contaminates exceed trigger values.

• All Monitoring results are to be available to DEC. • If there was any increase in pollutant levels due to the

operation of the power plant, the proponents will review the plant filtration and control processes accordingly.

Corrective Action

• Notify DEC where monitoring results exceed trigger values set out in contingency plan

• Implement contingency plan where pollutant contaminates exceed trigger values.

Amended and Additional Management Actions: High Risk stormwater has the potential to be generated within the areas surrounding hydrocarbon storage areas, workshop facilities, and any other locations where hydrocarbons and chemical substances are to be used or stored. High risk areas will be bunded, and where appropriate hydrocarbon and chemical storage areas will be roofed, or else these substances stored in-doors. Any stormwater collected in these areas will be either removed off-site for treatment or passed through oil-water separators and the waste collected and taken off-site by licensed contractors. For the biomass storage area, stormwater runoff and leachate will be directed into a retention pond that is hydrologically separate from the remainder of the stormwater system. This water will then be reused for dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant. For the remaining plant area of the site, stormwater will either be:

• Captured in a sediment pond for primary treatment, followed by secondary treatment if required in bioremediation devices to reduce nutrients, dissolved metals and other contaminants of concern via extended detention, vegetation, and/or soil filter medium, prior to discharge to the natural drainage catchment; or

• Captured in a holding pond and utilised for dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for process water.


PAGE 23

Any discharge of treated stormwater will be to the ambient water quality levels of the receiving water bodies. Should additional storage be required (i.e. dam expansion), the proponent would undertake the investigation required to report on potential impacts from decreased environmental flow on downstream water dependent ecosystems and identify how these impacts could be managed, prior to applying for the necessary approvals. Development of an onsite monitoring and water management program will be undertaken in consultation with the Department for Environment and Conservation and the Department of Water. The proponent will undertake an investigation and management process including representative sampling of drinking water supplies in the locality based on the Australian Drinking Water Guidelines 2004. Sampling is to include rainwater tank levels of polyaromatic hydrocarbons (PAH). The proponent will undertake an investigation and management process including representative sampling of surface dams in the locality prior to and during plant operations.


PAGE 24

3.2.6 Vegetation & Habitat Management


Construction

• As part of site induction and environmental awareness training, all construction staff will be informed of the environmental issues associated to the site and their obligations relating to construction activities

• Construction workers will be made aware of fauna movements and report the presence of fauna to the relevant either the project principal or supervisor.

• Prior to construction works commence a weed monitoring and control program to ensure that appropriate measures are undertaken to prevent the spread of Chamaecytisus palmensis (Tree Lucerne) and Rubus anglocandicans (Blackberry), to include: • Removal of identified weeds. • Chemical control in areas of denser weed infestation • Revegetating and restoring weeded areas with naturally occurring species as a

critical component of the weed removal process • No removal of native vegetation without regulatory approval. • Confine construction traffic to existing cleared areas. • Gravel and other raw materials used as part of the construction phase will be certified

as weed free • Soil removed from the site must be managed to prevent the spread of Dieback to

uninfested areas. • Seed heads and weeds with vegetation propagation capacity to be bagged and

disposed of in accordance with DEC guidelines. • Management of clearing and soil erosion as per Section 22.4.2. • If at any time during construction a significant impact on endangered wildlife listed

under the EPBC Act 1999 is considered likely, a referral to the Commonwealth government must be submitted.

• Prepare an overall construction Environmental Management Plan incorporating environmental management plans for Occupational Health & Safety (OHS) and fire prevention management.

Operation

• No further removal of native vegetation without regulatory approval • Maintain the existing State Forest barrier to create a visual buffer for the Plant and

chimney stack, while meeting the objectives of the fire management plan.

Construction


• Construction workers will be made aware of fauna movements and report the presence of fauna to the relevant either the project principal or supervisor.

• Prior to construction works commence a weed monitoring and control program to ensure that appropriate measures are undertaken to prevent the spread of Chamaecytisus palmensis (Tree Lucerne) and Rubus anglocandicans (Blackberry), to include: • Removal of identified weeds. • Chemical control in areas of denser weed infestation • Revegetating and restoring weeded areas with

naturally occurring species as a critical component of the weed removal process

• No removal of native vegetation without regulatory approval. • Confine construction traffic to existing cleared areas. • Gravel and other raw materials used as part of the

construction phase will be certified as weed free • Soil removed from the site must be managed to prevent the

spread of Dieback to uninfested areas. • Seed heads and weeds with vegetation propagation capacity

to be bagged and disposed of in accordance with DEC guidelines.

• Management of clearing and soil erosion as per Section 22.4.2.

• If at any time during construction a significant impact on endangered wildlife listed under the EPBC Act 1999 is considered likely, a referral to the Commonwealth government must be submitted.

• Prepare an overall construction Environmental Management


PAGE 25

• Implement Weed Control Management and Monitoring Plan. Monitoring & Reporting

• Weekly inspection to ensure vegetation outside the construction site is not being affected.

• Monitoring results are to be available to DEC. • Inspect vegetation growth. Record areas where re-planting is required for the

following year. • Regular inspection of vehicles and equipment entering and leaving the site.

Corrective Action Where fire management plan objectives can be met, revegetate with native species.

Plan incorporating environmental management plans for Occupational Health & Safety (OHS) and fire prevention management.

Operation

• No further removal of native vegetation without regulatory approval

• Maintain the existing State Forest barrier to create a visual buffer for the Plant and chimney stack, while meeting the objectives of the fire management plan.

• Implement Weed Control Management and Monitoring Plan. Monitoring & Reporting

• Weekly inspection to ensure vegetation outside the construction site is not being affected.

• Monitoring results are to be available to DEC. • Inspect vegetation growth. Record areas where re-planting is

required for the following year. • Regular inspection of vehicles and equipment entering and

leaving the site. Corrective Action Where fire management plan objectives can be met, revegetate with native

species. Amended and Additional Management Actions: Site induction environmental awareness training will include information regarding the locally publicly owned conservation and forest lands (national parks, nature reserves and State forest) and that staff are aware of requirements for appropriate behaviour in these areas. During both construction and operation site staff and contractors will be aware of general conditions relating to on-site disturbance, management of fire risk, weeds and soil protection in accordance with the CALM Act lease (proposed), subject to CALM Regulation amendments.


PAGE 26

Contractors/persons who are applying pesticides must be appropriately trained and hold a current pesticide License and be employed by a Registered Commercial Pest Firm. In general, pesticides must be applied in accordance with the Health (Pesticides) regulations 1956. All work is to be compliant with the approved Hygiene Management Plan on the adjoining harvested areas and a Dieback Hygiene Management Plan should be required for any earthworks that have the potential to spread the disease on State forest.


PAGE 27

3.2.7 Heritage & Cultural Management


Construction

• Comply with legislation and in the event an unrecorded archaeological site or deposit is uncovered, it would be reported to the Minister


Operation

• Comply with legislation and in the event an unrecorded archaeological site or deposit is uncovered, it would be reported to the Minister.

Monitoring & Reporting Maintain record for induction attendance. Corrective Action Ensure all obligations for reporting and notification under the Act and the assessment are carried out.

Construction

• Comply with legislation and in the event an unrecorded archaeological site or deposit is uncovered, it would be reported to the Minister


Operation

• Comply with legislation and in the event an unrecorded archaeological site or deposit is uncovered, it would be reported to the Minister.

Monitoring & Reporting Maintain record for induction attendance. Corrective Action Ensure all obligations for reporting and notification under the Act and the assessment are carried out. Amended and Additional Management Actions: Construction

• Comply with legislation and in the event any aboriginal or archaeological site is discovered, it would be reported to the Minister for Indigenous Affairs and managed in accordance with the requirements of the Aboriginal Heritage Act

• If a notice under section 18 of the Aboriginal Heritage Act needs to be submitted, the DIA needs to be contacted prior to commencing the application process and associated heritage surveys



PAGE 28

Operation

• Comply with legislation and in the event any aboriginal or archaeological site is discovered, it would be reported to the Minister for Indigenous Affairs

• The community reference group should include representation from local Aboriginal people if possible

Monitoring & Reporting Maintain record for induction attendance. Corrective Action Ensure all obligations for reporting and notification under the Aboriginal Heritage Act and the assessment are carried out.


PAGE 29

3.2.8 Air Quality Management


Construction


• Unsealed roads will be watered to suppress dust. • Restrict vehicle speed on unsealed roads to 20kph to limit dust generation. • No burning of waste materials or release to land or water. • Efficient use of construction machinery and earth moving equipment during

construction • All equipment used during construction to be maintained in good working order.

Operation

• Comply with State and Federal guidelines and prescribed licence conditions. • Ensure dust and other pollutants resulting from Power Plant operations are

minimised. • Base line monitoring program to be established prior to and during plant operation.

Monitoring will be carried out in accordance with the most relevant Australian or International Standards and DEC requirements

• Permanent automatic weather station established on site in accordance with AS2923 to log meteorological conditions on and surrounding the site.

• Develop and implement air quality monitoring program in accordance with DEC requirements, to include: � Real-time in-stack monitoring of gaseous and particulate matter will also be

used to qualify emissions and fuel. � A base-line monitoring program will be established prior to and during plant

operation (over a period of one year), which will include monitoring of; – Suspended Particulates - PM10 (and PM2.5) – TEOM or equivalent

sampling instrument (for hourly certification) is recommended. – Deposited Particulates (Dust) – Dust Gauge (no relevant Australian

Standard) – Gas - Nitrogen Dioxide

� All monitoring will be carried out in accordance with methods described in “Approved Methods for the Sampling and Analysis of Air Pollutants in New South Wales”. This guideline sets out best practice methods sourced from

Construction


• Unsealed roads will be watered to suppress dust. • Restrict vehicle speed on unsealed roads to 20kph to limit

dust generation. • No burning of waste materials or release to land or water. • Efficient use of construction machinery and earth moving

equipment during construction • All equipment used during construction to be maintained in

good working order. Operation

• Comply with State and Federal guidelines and prescribed licence conditions.

• Ensure dust and other pollutants resulting from Power Plant operations are minimised.

• Base line monitoring program to be established prior to and during plant operation. Monitoring will be carried out in accordance with the most relevant Australian or International Standards and DEC requirements

• Permanent automatic weather station established on site in accordance with AS2923 to log meteorological conditions on and surrounding the site.

• Develop and implement air quality monitoring program in accordance with DEC requirements, to include: � Real-time in-stack monitoring of gaseous and

particulate matter will also be used to qualify emissions and fuel.

� A base-line monitoring program will be established prior to and during plant operation (over a period of


PAGE 30

relevant Australian standards to determine sampling points as well as US EPA approved pollutant sampling procedures.

� Half yearly monitoring to be undertaken after one year of operation and subject to emissions targets being achieved.

� Baghouse controls to ensure maximum collection efficiency is not compromised as described herein.

� A weather station to be setup in accordance with AS2923, with the following minimum outputs averaged over 15 minutes: – Wind speed and direction at 10m – Temperature at 2m and 10m – Solar Radiation – Sigma-Theta at 10m

• Quality control methods and routine sampling of fuel to be established. • Baghouse controls to ensure maximum collection efficiency is not compromised. • In the event of a baghouse failure steps should be taken based on the plant hazard

and operability guidelines that there is minimal impact on the health of the surrounding residents and impact on local flora and fauna.


• Equipment to be inspected and approved by the Project Principal prior to location on site.

• Log of service and repairs to be kept by contractors and project staff. • Regular inspection of the emission control technology within the Power Plant. • Monitoring of the stack on commissioning and regular intervals thereafter of the

following gaseous pollutants. o Polycyclic aromatic hydrocarbons (PAHs) o Volatile organic compounds o Polychlorinated dioxins and furans o Sulphur dioxide o Carbon monoxide

• Real time in-stack continuous monitoring of the following gaseous and particulate matter. o Nitrogen Dioxide o PM10 o PM2.5

• Monitoring of plant efficiency • Implementation of quality control methods through sampling and analysis of fuel

one year), which will include monitoring of; – Suspended Particulates - PM10 (and PM2.5) –

TEOM or equivalent sampling instrument (for hourly certification) is recommended.

– Deposited Particulates (Dust) – Dust Gauge (no relevant Australian Standard)

– Gas - Nitrogen Dioxide � All monitoring will be carried out in accordance with

methods described in “Approved Methods for the Sampling and Analysis of Air Pollutants in New South Wales”. This guideline sets out best practice methods sourced from relevant Australian standards to determine sampling points as well as US EPA approved pollutant sampling procedures.

� Half yearly monitoring to be undertaken after one year of operation and subject to emissions targets being achieved.

� Baghouse controls to ensure maximum collection efficiency is not compromised as described herein.

� A weather station to be setup in accordance with AS2923, with the following minimum outputs averaged over 15 minutes: – Wind speed and direction at 10m – Temperature at 2m and 10m – Solar Radiation – Sigma-Theta at 10m

• Quality control methods and routine sampling of fuel to be established.

• Baghouse controls to ensure maximum collection efficiency is not compromised.

• In the event of a baghouse failure steps should be taken based on the plant hazard and operability guidelines that there is minimal impact on the health of the surrounding residents and impact on local flora and fauna.


• Equipment to be inspected and approved by the Project


PAGE 31

supply. Corrective Action Non-compliance is recorded and reported to the DEC.

Principal prior to location on site. • Log of service and repairs to be kept by contractors and

project staff. • Regular inspection of the emission control technology within

the Power Plant. • Monitoring of the stack on commissioning and regular

intervals thereafter of the following gaseous pollutants. o Polycyclic aromatic hydrocarbons (PAHs) o Volatile organic compounds o Polychlorinated dioxins and furans o Sulphur dioxide o Carbon monoxide

• Real time in-stack continuous monitoring of the following gaseous and particulate matter. o Nitrogen Dioxide o PM10 o PM2.5

• Monitoring of plant efficiency • Implementation of quality control methods through sampling

and analysis of fuel supply. Corrective Action Non-compliance is recorded and reported to the DEC. Amended and Additional Management Actions: Construction Submit and ensure compliance with conditions of Works Approval.

− Water sprays (hand held hoses or sprinklers) should be used during excavation activities where necessary to control visible dust.

− Stockpiles or material stores should be kept damp by water sprays and/or covered and should be located as far from residences as possible where necessary to control visible dust.

− Any stockpiles would be stored in sheltered locations where possible, with the slope of the upwind surface minimised.


PAGE 32

− Seal regularly trafficked roads/areas − cover all materials transported off site − ensure truck loads transported around the site are no taller than

the vehicle side walls as required to control visible dust − site access hardening, including laying grates, gravel pads, paving

or other hard surface at the site exit of sufficient length to remove soil and other material from vehicles.

− Regularly maintain diesel exhaust equipment and ensure compliance with appropriate design emission standards for in service vehicles.

− Maintain diesel powered stationary plant to ensure appropriate levels of air emissions and consider fitting emission controls where required.

Operation

• Fuel Handling Minimise any potential dust from delivery of fuel to the site.

• Fuel Quality Samples of fuel will be tested to ensure the correct fuel mix is maintained, and the fuel does not include treated (eg. Insecticides or other synthetic composites) waste material. Testing will be carried out on a monthly basis over the first year of operation, and thereafter 3 monthly for the life of the plant.

• Emissions Control: The fluidised bed combustion system will be controlled through monitoring the temperature within the boiler, excess air in the flue gas, as well as pollutant concentrations, to maximise combustion efficiency. Baghouse faults and efficiency will be detected by continuous real-time monitoring of the pressure either side of each filter media. Should the pressure difference change from a set range, the online section of the baghouse will immediately be taken off-line, and flue gas diverted to the standby section. The offline section will be repaired and reinstated for service. The baghouse will be shutdown on a regular basis for maintenance and inspection.


PAGE 33

• Air Dispersion Model Validation

Validate the dispersion model using results from monitoring.


• Monitoring will be required prior to plant operation, during the commissioning of the plant and post-commissioning, and will comprise: − Ambient air quality: This will involve continuously monitoring

criteria pollutants over the life of the plant at sensitive receptors around the plant (nominally 3 off). Continuous (hourly) monitoring of criteria pollutants will occur for 12 months prior (Baseline Monitoring) to plant operation, for 12 months after commissioning, and thereafter for a one month period every 6 months for the life of the plant. Air toxics will be monitored on a monthly basis for the first year of operation, and thereafter every 6 months.

− In-stack Monitoring: Real-time continuous in-stack monitoring will be carried out to control plant operations, ensure compliance with emissions guarantees, and for external auditing for quality assurance

− Meteorological Monitoring: A permanent automatic weather station will be installed at the site to log weather conditions on an hourly basis prior to construction, and throughout the operational life of the plant.

• Monitoring will include but not be limited to criteria pollutants (NO2,

SO2, CO, O3, Pb, PM10, PM2.5) and air toxic pollutants (PAH, PCDD/F, Trace Elements).

• Ambient air monitoring at sensitive receptors around the plant, together

with real-time in-stack monitoring will be carried out. Monitoring methods will comply with Australian Standards (or International Standards if Australian Standards are not developed).

Corrective Action Any exceedance will be immediately investigated and if it cannot be rectified in a reasonable time, the plant will be shutdown.


PAGE 34

3.2.9 Noise Management


Construction


• Limit construction activities to the following time restrictions; • Monday to Saturday – 7am to 7pm • No work on Sundays or Public Holidays • All plant and machinery to be in good working order with optional mufflers where

required • Construction work carried out in accordance with Section 6 of AS 2436-1981 • Create a log and assessment of complaints, as well as routine monitoring of noise

levels during construction • Construction activities will be limited to time restrictions described in Noise quality

assessment section of this report. • Low noise machinery will be applied where possible. • Stationery equipment such as air compressors and generators will be placed away

from noise sensitive areas. • In advance notification will be provided to community regarding noise disruptions. • Temporary structures or screens will be erected to limit noise exposure.

Operation

• Develop and implement an operational noise management plan as part of the final design stage.

• Equipment installed/constructed at the power plant should comply with the noise limits contained in Table 14.8 of this report.

• Certification of the design shall be undertaken by a suitably qualified Acoustic Engineer.

• Compliance measurements shall be undertaken by a suitably qualified Acoustic Engineer.

• Noise monitoring will initially be undertaken over a period of one month, with automated and manned monitoring carried out. Automated monitoring will comprise of a fixed monitor at the residential boundary, logging statistical data at 15 minute intervals. Manned monitoring will involve manual spot monitoring to validate the logger results and provide additional monitoring around the site.

Construction


• Limit construction activities to the following time restrictions; • Monday to Saturday – 7am to 7pm • No work on Sundays or Public Holidays • All plant and machinery to be in good working order with

optional mufflers where required • Construction work carried out in accordance with Section 6

of AS 2436-1981 • Create a log and assessment of complaints, as well as

routine monitoring of noise levels during construction • Construction activities will be limited to time restrictions

described in Noise quality assessment section of this report. • Low noise machinery will be applied where possible. • Stationery equipment such as air compressors and

generators will be placed away from noise sensitive areas. • In advance notification will be provided to community

regarding noise disruptions. • Temporary structures or screens will be erected to limit noise

exposure. Operation

• Develop and implement an operational noise management plan as part of the final design stage.

• Equipment installed/constructed at the power plant should comply with the noise limits contained in Table 14.8 of this report.

• Certification of the design shall be undertaken by a suitably qualified Acoustic Engineer.

• Compliance measurements shall be undertaken by a suitably


PAGE 35

• Manned monitoring will be undertaken every three months during the first year of operation and than six monthly intervals therein.

• Limiting material handling to daytime hours. Monitoring & Reporting

• Record complaints and make available to DEC when requested. • Routine monitoring of noise levels at sensitive receptors. • Regular maintenance inspections of plant equipment and repair and replace where

applicable. • Maintain and inspect noise control measures • Automated and manned monitoring undertaken onsite

Corrective Action

• If work is to be undertaken outside the allocated timeframe residents will be notified in advance.

• Repairs or replace equipment where required.

qualified Acoustic Engineer. • Noise monitoring will initially be undertaken over a period of

one month, with automated and manned monitoring carried out. Automated monitoring will comprise of a fixed monitor at the residential boundary, logging statistical data at 15 minute intervals. Manned monitoring will involve manual spot monitoring to validate the logger results and provide additional monitoring around the site.

• Manned monitoring will be undertaken every three months during the first year of operation and than six monthly intervals therein.

• Limiting material handling to daytime hours. Monitoring & Reporting

• Record complaints and make available to DEC when requested.

• Routine monitoring of noise levels at sensitive receptors. • Regular maintenance inspections of plant equipment and

repair and replace where applicable. • Maintain and inspect noise control measures • Automated and manned monitoring undertaken onsite

Corrective Action

• If work is to be undertaken outside the allocated timeframe residents will be notified in advance.

Repairs or replace equipment where required. Amended and Additional Management Actions: Submit, and ensure compliance with, conditions of Works Approval.


PAGE 36

3.2.10 Waste Management


Construction

• As part of site induction and environmental awareness training, all construction staff will be informed of the environmental issues associated with the site and their obligations relating to construction activities.

• Minimise packaging of construction materials to be delivered to the site to avoid excessive waste production.

• Reduce the quantity of solid waste to landfill through implementation of waste reduction initiatives, reuse and recycling practices

• Storage and handling of hydrocarbons will be conduct in accordance with Australian Standards for Storage and Handling of Flammable and Combustible Liquids (AS1940) and other relevant Australian Standards.

• Transportation of dangerous goods will be undertaken in accordance with Dangerous goods (Transport) Act 1998.

• All waste to be removed from construction areas as soon as practicable and in accordance with EPA Regulations.

• No burning of waste materials on the site. • Domestic wastewater generated from the construction camp will be discharged into a

septage treatment system. • Controlled waste will be collected by a licensed contractor and disposed off-site to a

licence facility in accordance with Environmental Protection (Controlled Waste) Regulations 2004.

Operation

• A zero process water discharge policy to the environment applies for the operation of the power plant.

• Use of recyclable packing material. • Waste handling and disposal procedures will be incorporated into operating manuals

and induction training sessions for employees, visitors and contractors. • Minimise volumes of solid waste to landfill through reuse and recycling programs. • Utilise appropriate waste and disposal facilities as with current practices • Boiler blowdown, EDI effluent and demineralised process wastewater will be

discharged to an ash wetting storage tank to be used in the ash wetting process. • Domestic wastewater will be discharged and treated through a septic disposal

system. Wastewater discharged from the septic system will comply with Health

Construction

• As part of site induction and environmental awareness training, all construction staff will be informed of the environmental issues associated with the site and their obligations relating to construction activities.

• Minimise packaging of construction materials to be delivered to the site to avoid excessive waste production.

• Reduce the quantity of solid waste to landfill through implementation of waste reduction initiatives, reuse and recycling practices



• All waste to be removed from construction areas as soon as practicable and in accordance with EPA Regulations.

• No burning of waste materials on the site. • Domestic wastewater generated from the construction camp

will be discharged into a septage treatment system. • Controlled waste will be collected by a licensed contractor

and disposed off-site to a licence facility in accordance with Environmental Protection (Controlled Waste) Regulations 2004.

Operation

• A zero process water discharge policy to the environment applies for the operation of the power plant.

• Use of recyclable packing material. • Waste handling and disposal procedures will be incorporated

into operating manuals and induction training sessions for employees, visitors and contractors.

• Minimise volumes of solid waste to landfill through reuse and


PAGE 37

(Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974 and the local Country Sewerage Policy

• Sludge generated from the septage treatment unit is classified as ‘controlled waste’ under Environmental Protection (Controlled Waste) Regulations 2004. It will be collected by a licensed carrier and treated off-site at a licence facility, in accordance with Department of Environment Controlled Waste Treatment or Disposal Site Guideline No.3 March 2004.

• Stormwater run-off from low risk areas will be discharged to a stormwater pond. • Stormwater run-off from hydrocarbon storage areas will be discharged to an oil-water

interceptor with treated stormwater then discharged to the stormwater pond. • Hydrocarbon storage areas will be bunded. • Waste from the oily-water interceptor will be collected and disposed of as required by

an external licensed contractor. • Controlled waste will be collected by a licensed contractor and disposed off-site to a

licence facility in accordance with Environmental Protection (Controlled Waste) Regulations 2004.



• The disposal of furnace ash will be undertaken in accordance with Department of Environmental guidelines ‘Landfill Waste Classification and Waste Definitions WA (2002).

• Rainwater tanks will be fitted to major roof areas to supplement potable water requirements.


• Regular inspections of the sites waste storage and disposal facilities, including visual inspection of litter and general waste within and around the site perimeter will be undertaken.

• Record volumes of solid waste recycled and disposed to landfill. • Inspect hydrocarbon bunds. • Record volumes of controlled waste collected and disposed off site. • Regular inspection and monitoring of the septage treatment unit will be employed to

ensure the quality of wastewater meets acceptance criteria. Quarterly inspection of

recycling programs. • Utilise appropriate waste and disposal facilities as with

current practices • Boiler blowdown, EDI effluent and demineralised process

wastewater will be discharged to an ash wetting storage tank to be used in the ash wetting process.

• Domestic wastewater will be discharged and treated through a septic disposal system. Wastewater discharged from the septic system will comply with Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974 and the local Country Sewerage Policy

• Sludge generated from the septage treatment unit is classified as ‘controlled waste’ under Environmental Protection (Controlled Waste) Regulations 2004. It will be collected by a licensed carrier and treated off-site at a licence facility, in accordance with Department of Environment Controlled Waste Treatment or Disposal Site Guideline No.3 March 2004.

• Stormwater run-off from low risk areas will be discharged to a stormwater pond.

• Stormwater run-off from hydrocarbon storage areas will be discharged to an oil-water interceptor with treated stormwater then discharged to the stormwater pond.

• Hydrocarbon storage areas will be bunded. • Waste from the oily-water interceptor will be collected and

disposed of as required by an external licensed contractor. • Controlled waste will be collected by a licensed contractor

and disposed off-site to a licence facility in accordance with Environmental Protection (Controlled Waste) Regulations 2004.



• The disposal of furnace ash will be undertaken in


PAGE 38

the septage treatment unit will be undertaken for maintenance purposes. • Regular inspection and monitoring of septic disposal system. • Record volumes and composition of ash disposed off site. • A Stormwater Monitoring plan will be developed in consultation with the Department

of Environment and Conservation and Department of Water. • Monitoring results will be made available to the Department of Environment and

Conservation. Corrective Action Non-compliance is recorded and reported to the DEC.

accordance with Department of Environmental guidelines ‘Landfill Waste Classification and Waste Definitions WA (2002).

• Rainwater tanks will be fitted to major roof areas to supplement potable water requirements.


• Regular inspections of the sites waste storage and disposal facilities, including visual inspection of litter and general waste within and around the site perimeter will be undertaken.

• Record volumes of solid waste recycled and disposed to landfill.

• Inspect hydrocarbon bunds. • Record volumes of controlled waste collected and disposed

off site. • Regular inspection and monitoring of the septage treatment

unit will be employed to ensure the quality of wastewater meets acceptance criteria. Quarterly inspection of the septage treatment unit will be undertaken for maintenance purposes.

• Regular inspection and monitoring of septic disposal system. • Record volumes and composition of ash disposed off site. • A Stormwater Monitoring plan will be developed in

consultation with the Department of Environment and Conservation and Department of Water.

• Monitoring results will be made available to the Department of Environment and Conservation.

Corrective Action Non-compliance is recorded and reported to the DEC. Amended and Additional Management Actions: High risk areas will be bunded, and where appropriate hydrocarbon and chemical storage areas will be roofed, or else these substances stored in-doors. Any stormwater collected in these areas will be either removed off-


PAGE 39

site for treatment or passed through oil-water separators and the waste collected and taken off-site by licensed contractors. For the biomass storage area, stormwater runoff and leachate will be directed into a retention pond and the water reused for dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant. For the remaining plant area of the site, stormwater will either be:

• Captured in a sediment pond for primary treatment, followed by secondary treatment if required in bioremediation devices to reduce nutrients, dissolved metals and other contaminants of concern via extended detention, vegetation, and/or soil filter medium, prior to discharge to the natural drainage catchment; or

• Captured in a holding pond and utilised for dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for process water.

A sampling and management strategy for both furnace and fly ash will be developed. Ash sampling is to include heavy metals, Dioxin/Furans (PCDD/F TEQ) and PAH’s analysis in the sampling program. Should the fly ash be suitable to be disposed of on land for agricultural purposes (as a soil enrichment agent) it will be removed from the storage area for this purpose. If not, and if there is no alternative use for the ash product, disposal will be undertaken in accordance with Department of Environmental guidelines ‘Landfill Waste Classification and Waste Definitions WA (2002).


PAGE 40

3.2.11 Hazard and Risk Management


Construction


• Implement quality control measures in equipment construction. • Provide appropriate PPE gear for all personnel. • All plant equipment will have physical guarding to minimise potential interaction with

equipment or personnel. • Equipment and machinery will have appropriate noise control measures. • Spill kits, fire fighting equipment and fire fighting water supply located on site. • All construction equipment will be quality controlled.

Operation

• Provide appropriate PPE gear for all personnel. • Stock piles will be built in a rectangular form, with the narrow end of the rectangle facing the

prevailing winds. • Appropriate management of biomass fuel storage to avoid self combustion. • Enclosed conveyor belt and suitable ventilation and dust management controls. • All plant equipment will have physical guarding to minimise potential interaction with

equipment or personnel. • Equipment and machinery will have appropriate noise control measures. • Bunding of chemicals and dangerous goods on site. • Transportation of dangerous goods will be undertaken in accordance with Dangerous goods

(Transport) Act 1998. • Storage and handling of hydrocarbons and chemicals will be conduct in accordance with

Australian Standards for Storage and Handling of Flammable and Combustible Liquids (AS1940) and other relevant Australian Standards.

• Prepare a detailed Risk Management and Emergency Response as part of final design. • A Hazard and Operability study (HAZOP) to be carried out as part of the detail design of the

project. • Truck trailers will be enclosed or covered. • Spill kits to be located on site • Enclosed drainage system to prevent water discharge to the environment.

Construction


• Implement quality control measures in equipment construction.

• Provide appropriate PPE gear for all personnel. • All plant equipment will have physical guarding to

minimise potential interaction with equipment or personnel.

• Equipment and machinery will have appropriate noise control measures.

• Spill kits, fire fighting equipment and fire fighting water supply located on site.

• All construction equipment will be quality controlled. Operation

• Provide appropriate PPE gear for all personnel. • Stock piles will be built in a rectangular form, with the

narrow end of the rectangle facing the prevailing winds.

• Appropriate management of biomass fuel storage to avoid self combustion.

• Enclosed conveyor belt and suitable ventilation and dust management controls.

• All plant equipment will have physical guarding to minimise potential interaction with equipment or personnel.

• Equipment and machinery will have appropriate noise control measures.

• Bunding of chemicals and dangerous goods on site. • Transportation of dangerous goods will be undertaken


PAGE 41


• Regular equipment maintenance and testing of plant equipment including loading vehicles. • Monthly inspection of fire fighting equipment and water supply. • Weekly inspection of plant equipment and guards. • Inspect and record the temperature of stockpiles on a daily basis. • Weekly inspection of bunds. • Regular monitoring and management of ash handling and fuel supply system.

Corrective Action

• Repair and / or replace guarding on plant equipment where required. • Where plant equipment and machinery are non compliant cease use and either repair and or

replace. • Implement site contingency plan and emergency response plan.

in accordance with Dangerous goods (Transport) Act 1998.

• Storage and handling of hydrocarbons and chemicals will be conduct in accordance with Australian Standards for Storage and Handling of Flammable and Combustible Liquids (AS1940) and other relevant Australian Standards.

• Prepare a detailed Risk Management and Emergency Response as part of final design.

• A Hazard and Operability study (HAZOP) to be carried out as part of the detail design of the project.

• Truck trailers will be enclosed or covered. • Spill kits to be located on site • Enclosed drainage system to prevent water discharge

to the environment. Monitoring & Reporting

• Regular equipment maintenance and testing of plant equipment including loading vehicles.

• Monthly inspection of fire fighting equipment and water supply.

• Weekly inspection of plant equipment and guards. • Inspect and record the temperature of stockpiles on a

daily basis. • Weekly inspection of bunds. • Regular monitoring and management of ash handling

and fuel supply system. Corrective Action

• Repair and / or replace guarding on plant equipment where required.

• Where plant equipment and machinery are non compliant cease use and either repair and or replace.

• Implement site contingency plan and emergency response plan.


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Amended and Additional Management Actions: Response to vehicle accidents such as truck rollovers that occur on public roads would occur through the respective emergency services (police, fire brigade, ambulance) and be addressed through the site safety and emergency response procedures. It is anticipated these site specific documents and procedures would be prepared prior to operations commencing.


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3.2.12 Fire Management


Construction

• A detailed Fire Management Plan will be prepared in accordance with the requirements outlined in Planning for Bushfire Protection (WAPC 2001) and submitted to the South West Department of Environmental and Conservation for review as part of the final design stage.

• The Fire Management Plan will incorporate management regimes for the Building and Hazard Separation Zones.


• Smoking to be prohibited on site. • Fire fighting equipment located on site and meet Australia Standards

Operation

• Smoking to be prohibited on site. • Hazard Separation Zones and Building Protection Zones will be maintained in accordance with Planning

for Bushfire Protection (WAPC 2001) to ensure low fuel levels are maintained. • Fire fighting equipment located on site and meet Australia Standards • The fuel yard and complete power station will have fire detection, suppression and fighting system. The fire

hydrants will extensively cover the fuel yard. • Management of biomass storage to avoid self combustion. • Stock piles will be built in a rectangular form, with the narrow end of the rectangle facing the prevailing

winds Monitoring & Reporting

• Weekly inspection of equipment and fire fighting equipment. • The temperature of the stock piles will be measured daily to monitor and control the temperature of the

pile, ensuring it does not exceed over what is considered a safety limit. • Annual auditing of the Fire Management Plan. • Report incidents to Project principal and or Site Supervisor.

Corrective Action

• Replace equipment that fails to meet Australian Standards • Where fire can not be managed the Emergency Response Plan (as stated in Hazard & Risk EMP above)

to be activated

Construction

• A detailed Fire Management Plan will be prepared in accordance with the requirements outlined in Planning for Bushfire Protection (WAPC 2001) and submitted to the South West Department of Environmental and Conservation for review as part of the final design stage.

• The Fire Management Plan will incorporate management regimes for the Building and Hazard Separation Zones.


• Smoking to be prohibited on site. • Fire fighting equipment located on site and meet

Australia Standards Operation

• Smoking to be prohibited on site. • Hazard Separation Zones and Building Protection

Zones will be maintained in accordance with Planning for Bushfire Protection (WAPC 2001) to ensure low fuel levels are maintained.

• Fire fighting equipment located on site and meet Australia Standards

• The fuel yard and complete power station will have fire detection, suppression and fighting system. The fire hydrants will extensively cover the fuel yard.

• Management of biomass storage to avoid self combustion.

• Stock piles will be built in a rectangular form, with


PAGE 44

the narrow end of the rectangle facing the prevailing winds


• Weekly inspection of equipment and fire fighting equipment.

• The temperature of the stock piles will be measured daily to monitor and control the temperature of the pile, ensuring it does not exceed over what is considered a safety limit.

• Annual auditing of the Fire Management Plan. • Report incidents to Project principal and or Site

Supervisor. Corrective Action

• Replace equipment that fails to meet Australian Standards

• Where fire can not be managed the Emergency Response Plan (as stated in Hazard & Risk EMP above) to be activated


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3.2.13 Social and Economic Impact Management


Construction


• Minimise noise levels from construction activities through time restrictions described in Section 14 of this report.

• Retain vegetation buffer to improve visual amenity. • Use local contractors where applicable skills exist.

Operation

• Limit truck movements over weekends and restrict normal delivery times for weekdays between 7:00am -7:00pm.

• Community participation and input in on-going planning, detailed design, management and monitoring.

• Monitoring program in accordance with outcomes of detailed environmental investigations • Ongoing community information program about safe pollutant and noise levels • Publication of information on the project’s compliance • Local training programs and employees skills development • Convening of a Community Reference Group which interacts with the proponents as an

ongoing basis about the social impacts of the plant operations. Monitoring & Reporting

• Record fuel delivery times. • Review complaints register • Monitor CRG feedback

Corrective Action Re-vegetate where required.

Construction


• Minimise noise levels from construction activities through time restrictions described in Section 14 of this report.

• Retain vegetation buffer to improve visual amenity. • Use local contractors where applicable skills exist.

Operation


• Community participation and input in on-going planning, detailed design, management and monitoring.

• Monitoring program in accordance with outcomes of detailed environmental investigations

• Ongoing community information program about safe pollutant and noise levels

• Publication of information on the project’s compliance • Local training programs and employees skills development • Convening of a Community Reference Group which interacts with

the proponents as an ongoing basis about the social impacts of the plant operations.


• Record fuel delivery times. • Review complaints register • Monitor CRG feedback

Corrective Action Re-vegetate where required. Amended and Additional Management Actions:


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The community reference group should include representation from local Aboriginal people if possible


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3.2.14 Traffic and Transport Management


Construction

• A main entry and exit point is designated for trucks entering or leaving the site through a one way system.

• Access to adequate and clearly marked staff and visitor parking on site. Operation


• A main entry and exit point is designated for trucks entering or leaving the site. • Entry/exit points will be clearly signed and onsite speed limits enforced. • Ensuring that road signage on key access roads (particularly Palings Road, Eastbourne

Road and the South West Highway) is adequate. • Contact details will be provided to the public for complaints, this may be displayed on the

trucks or made available through Community Reference Group (CRG) and proponents website

• Pedestrian walkways will be clearly defined on site to ensure the safety of employees, contractors and visitors.


• Record delivery times. • Check presence and condition of signage. • Visually inspect the condition of the walkways.

Corrective Action

• Review complaints register • Monitor CRG feedback

Construction

• A main entry and exit point is designated for trucks entering or leaving the site through a one way system.

• Access to adequate and clearly marked staff and visitor parking on site.

Operation


• A main entry and exit point is designated for trucks entering or leaving the site.

• Entry/exit points will be clearly signed and onsite speed limits enforced.

• Ensuring that road signage on key access roads (particularly Palings Road, Eastbourne Road and the South West Highway) is adequate.

• Contact details will be provided to the public for complaints, this may be displayed on the trucks or made available through Community Reference Group (CRG) and proponents website

• Pedestrian walkways will be clearly defined on site to ensure the safety of employees, contractors and visitors.


• Record delivery times. • Check presence and condition of signage. • Visually inspect the condition of the walkways.

Corrective Action

• Review complaints register • Monitor CRG feedback

Amended and Additional Management Actions: A road safety audit assessing relevant road systems will be carried out at the detailed design stage in accordance with specific rules and checklists


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by an independent specially trained and qualified person, leading a team with road safety and design experience, in consultation with the Shire of Manjimup and Main Roads WA. No truck movements for biomass fuel supply will occur on Sundays. WA Biomass and its contractors will obtain the necessary transport permits from the DEC, Shire of Manjimup and/or Main Roads WA.


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4. Response to Submissions

4.1 Fuel Supply

A sustainable and viable fuel supply is fundamental for a power station operation. Various submissions commented on aspects associated with the fuel supply for the proposed plant. Comments were received outlining the benefits of utilising a resource (i.e. the plantation waste) that is currently being wasted. However, of primary concern was the potential use of native forest material as a fuel source. Concerns were also raised as to how the fuel specification could be managed and the potential for impact of collection of the plantation waste on soil quality in the plantation. It was also suggested that non-timber products might be used as fuel in the plant. The PER (p.42) has clearly stated that the proponents will only be using plantation waste in the fuel processes for the Plant. There is no intention (now or at any time in the future) to accept waste material from clearing of harvesting of native forest as a feed source for the plant. This for the following reasons: • The process design for the Plant is based solely on this fuel supply. It is not realistic to suggest

that other fuel supplies (e.g. non-timber products) could be considered given the extent of investment ($110 Million) in the plant technology and the importance that fuel quality plays in Plant processes.

• To have the Plant accredited as a renewable energy project, the Plant cannot use native vegetation or any other fuel that is unable to be audited as a renewable energy fuel.

The biomass fuelled Power Plant appears to satisfy the requirements for eligibility as an accredited renewable energy Power Plant that is able to create Renewable Energy Certificates (RECs). To claim RECs the operation must be eligible for RECs from an eligible fuel source. Only accredited renewable energy power stations are eligible to claim RECs. The proponents are prepared to commit to use of plantation waste only through a lease or licence condition. This is the basis on which WA Biomass has tendered to Synergy for the purchase of this renewable energy. The Australian Government Office of the Renewable Energy Regulator administers the wood waste eligibility assessment for determining accreditation for renewable energy Power Plants that are able to create Renewable Energy Certificates. The details of eligibility criteria are summarised below. The proposed plantation waste fuel is eligible under Category 6: wood waste from plantations. The regulations contain a number of elements that are essential in demonstrating the eligibility of wood waste produced from a plantation. (6) Wood waste from a plantation must be: (a) a product of a harvesting operation (including thinnings and coppicing): (i) approved under relevant Commonwealth, State or Territory planning and approval processes; and (ii) for which no product of a higher financial value than biomass for energy production could be produced at the time of harvesting; and

(b) biomass: (i) managed in accordance with a code of practice approved under regulation 4B of the Export Control (Unprocessed Wood) Regulations; and (ii) taken from land that was not cleared of native vegetation after 31 December 1989 for the purpose of establishing the plantation

Four major suppliers are contracted to provide the plantation waste as fuel supply for this proposal, consisting of pine and bluegum plantation waste that is eligible under the above wood waste eligibility criteria. Details of the contracts to supply this timber follow, demonstrating the ability of the suppliers to adequately meet the fuel supply demand of the plant in the long term


PAGE 50

� WA Forest Products Commission Timber Residue Agreement includes pine thinnings as the fuel source. The minimum volumes of fuel to be supplied over 20 years include at least 160,000 tonnes pa for first 10 years, at least 100,000 tonnes pa for the second ten years. The contract refers to termination date 20 years after the commencement date which is when the facility commences to use plantation residues, and the contract includes a provision to negotiate to extend the term of the agreement. The contract also states that the buyer/contractor must comply with the:

- Environmental Management System - Code of Practice for Timber Plantations in WA - Timber Harvesting Manual (Plantations)

� Integrated Tree Cropping Limited Fuel Supply Agreement states that all fuel produced from its

plantation harvesting operations in the Plantation Area presented at roadside, in accordance with the Seller’s normal forestry practice, will be purchased by WA Biomass, who will process and cart the residue from roadside. The agreement states that the sellers plantation area is approximately 16,000 ha which is expected to yield 80,000 tpa. The agreement states the buyer shall ensure that all processing and haulage contractors have undertaken to comply with Standards of Practice as published by the Forest Stewardship Council of Australian Forestry Standards. The initial term of this agreement shall expire 5 years after commencement date and following the initial period this agreement will be automatically renewed for successive periods of five (5) years.

� The WA Chip and Pulp Co Pty Ltd Fuel Supply Agreement states fuel produced from the Seller’s

Harvesting Operations in the Plantation Area will be purchased by WA Biomass. In accordance with the Seller’s Harvesting Schedule there is likely to be 150,000 Tonnes of Fuel available under this Agreement for collection and processing prior to delivery to the Facility. The Seller agrees to make available for sale to the Buyer in each Operating Year all the Fuel produced from the Seller’s Harvesting Operations in the Plantation Area, in accordance with the Seller’s Harvesting Schedule. WA Chip and Pulp Co shall ensure that all relevant Fuel is deposited at the roadside in windrows conforming to normal forestry practice. All Processing Contractors and Haulage Contractors have undertaken to comply with Standards of Practice as published by the Forest Stewardship Council or Australian Forestry Standards and the Seller’s management system policies and procedures in force at the time. WA Biomass shall ensure that the Contractors will operate in accordance with the Seller’s operational policies and procedures which have been delivered to the Buyer in written form. The Seller shall deliver such operational policies and procedures in written form to the Buyer, including any changes from time to time. The initial term of the agreement shall expire 7 years after commencement date and following the initial period this agreement will be automatically renewed for successive periods of five (5) years.

� Great Southern Managers Australia Limited Fuel Supply Agreement states that it will make

available for sale to WA Biomass in each Operating Year all the Fuel produced from the Seller’s Harvesting Operations from either:

(i) the number of Planted Hectares which the Seller harvests in that Operating Year within the Plantation Area (which number of Planted Hectares will be determined by the Seller in the Seller’s absolute discretion); or (ii) the number of Planted Hectares for that Operating Year set out in Schedule 4,whichever is the lesser. The estimated number of hectares to be harvested pa is 300 years 2009-2014, years 2014- 2020 is 3000ha pa.

WA Biomass shall ensure that all Processing Contractors and Haulage Contractors have undertaken to comply with the Standards of Practice. Great Southern shall ensure that the contractors will operate in accordance with the Seller's operational procedures which have been delivered to the Buyer in written form, including without limitation the Seller’s occupational, health, safety and environmental policies from time to time. The initial term of the agreement expires in 30 June 2020 and following the initial period this agreement will be automatically renewed for successive periods of five (5) years.


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A Report on Forestry Aspects of the Synergy Displacement Tender (Fifth Estate, March 2008) involved a review of the proposed fuel supply, including:

• The availability and sustainability of the required quantity of wood and forest based fuel, • The proposed purchase contracts under which the wood and forest based fuels will be

procured, • The suppliers; capacity to meet the quantity and quality of wood and forest based fuels

specified in the purchase contracts, • The capacity of the fuel suppliers and/or the proponent to, where relevant, harvest, gather,

collect and transport the wood and forest based fuels, • The reasonableness and sustainability of the costing associated with the procurement,

harvesting, gathering, collecting and transporting of the wood and forest based fuels, • Any other risks associated with the supply of wood and forest based fuel.

The report by Fifth Estate is provided in Appendix A. It finds that there is adequate volume in the region to supply the necessary 380,000 tonnes of biomass for the power station. The report concludes that:

• There is little risk of WA Biomass not being able to secure the necessary volume of biomass fuel on a sustainable basis.

• The removal of residues following harvesting provides both an operational and financial benefit for the plantation owners and managers. The removal of plantation residues reduces the cost and increases the area available for replanting.

• The plantations from which the radiate pine supply is based are already established and will be harvested over the next 30 years.

• Much of the bluegum plantation base is owned and managed by companies operating Managed Investment Schemes. These operations have recently been through a Federal Government review and the Government has announced policies continuing to support the industry.

• The biomass estimates are supported by research using “imperial” (using actual measured data) and “process” (where sophisticated models calibrated using actual measured data) model results.

All fuel supply contracts involve commitments to provide fuel until the end of the committed plantation cycle. The contracts provide for renewal provisions for resources planted in the future but this will be subject to commercial agreement at that time. Independent expert industry advice suggests that likely future planting patterns will result in fuel supply to be available beyond this period. The proponents are taking the commercial risk on this being so, rather than considering alternative fuel supply options such as use of native forest resources. Correspondence detailing the management practices of the contracted suppliers is provided in Appendix B. The correspondence demonstrates that under current practices the plantation waste would be burned in the open field to allow replanting. Notably there is some 30,000 tonnes of woodwaste currently produced by the Diamond Mill which is currently burned in an uncontrolled manner. This comprises waste from plantations (bluegum) and native forest (Karri thinnings). WA Biomass will only utilise the component of this fuel that is derived from plantations, provided that it is practicable to do so. Table 4-1 Fuel Supply Issues & Statements

Issue/Statement Submission No.

Response

FUEL SPECIFICATION

- How will 43% moisture content be contained for material to be burned, as it has been suggested that moisture content increases emissions.

6, 41, 17, 30, 31, 52, 53

The fuel specification is based on extensive tests, including winter periods of the fuel type to establish moisture levels. The Fuel Specification represents the upper limit, or outer range,


PAGE 52

- What is the expected variation in fuel specification for Tables 3-3 and 13-1

identified from the field testing of the fuel supply. Fuel analysis undertaken by the proponents was based upon fuel collected, processed and analyzed (in the HRL laboratory) in winter conditions, which yielded an approximate composite moisture level of 43%. Fuel analysis based upon fuel collected, processed and analyzed in summer conditions yielded an approximate composite moisture level of 22%. The moisture contents of the two samples analyzed in winter and summer are a reasonable expectation of the fuel supply extremes in Western Australia which will be presented to the boiler under normal steady-state conditions. The optimal design solution was to arrange the boiler design and arrangement that encompasses the range of fuels to be presented to the boiler. In this case the proposed boiler must be capable of accepting fuel with a moisture range of 22% to 43% with continuous rated net output maintained in all cases.

Calculate emissions for 60% moisture (worst case)

6

This is not necessary as the field tests have proven that the fuel specification can be met, and the fuel feed can be managed in order to meet the required specifications. This is based on the outcomes of field tests under extreme local conditions (see above).

A covered area is established for sufficient fuel quantities to meet moisture specifications. Fuel that meets moisture specification be segregated.

6

The proponent has developed a fuel specification that it commits to meeting during operation of the plant. It is anticipated that a temporary storage facility may suffice. Should there be a requirement for a permanent facility to store fuel for drying purposes this will be designed at the detailed design stage.

USE OF PLANTATION WASTE

Need to reference or provide guidelines/legislation to support following statement: Sec - 3.5 "To have the Plant accredited as renewable energy project, the Plant cannot use native vegetation or any other fuel that is unable to be audited as a renewable energy fuel".

52

This statement refers to timber waste that is eligible under the Australian Government Office of the Renewable Energy Regulator wood waste eligibility criteria. The details of eligibility criteria are provided in detail above. The proponents propose that the EPA licence the plant to only utilise plantation wood waste.

- Western Australian Forest Alliance understands that the proposed Biomass plant will not be allowed to use native forest 'products' as fuel. - Must only use exotic plantation wood from land that has been previously cleared, i.e. native forest or vegetation must not be cleared to grow plantations of exotic species for bioenergy

GS1, 27, 30, 42, 47, 48, 53, 54, 64, 65, 66

The various submissions relating to the potential for use of native forest products are addressed above. The biomass power plant will only use timber waste that is eligible under the Australian Government Office of the Renewable Energy Regulator wood waste eligibility criteria. The main suppliers of plantation waste have contracts in place demonstrating the ability of the suppliers to adequately meet the fuel supply


PAGE 53

- Opposed to further clearing of native vegetation in the already over-cleared south west of WA - Pressure on Shires native forests for fuel supplies - The EPA to ask the proponent if it has approached the Forest Products Commission enquiring about access to native forest derived fuel, and if so, whether the proponent envisages use of native forest derived fuel within the fuel mix for up to the 40MW generation capacity, and/or for expansion 40MW capacity. the EPA should verify the proponent's response with the Forest Products Commission. - Not confident in the guarantees that currently exist as to the fuel sources that will be sourced by the plant. - It is recommended that the EPA oppose use of Karri, Jarrah and Marri from native forests as fuel for biomass power generation at Diamond Mill and elsewhere in WA. - Recommends that there be a Ministerial Condition imposed on the proponent preventing the use of native forest materials

demand of the plant in the long term. Therefore there is no need, or intention, for the proponents to contemplate the use of native forest products. The opportunity to utilise the timber mill waste from the adjacent site, which is currently stockpiled and burnt, has been identified but can only proceed if the wood waste meets the eligibility criteria. The proponents are willing to commit to a condition on the licence confining the proposal to the use of plantation waste products only.

Insignificant fuel input from Mill (20 days) 11, 12,

The proponent will only utilise waste material from the mill that can be verified as sourced from plantations. It is to be noted that the PER does not assume that this volume of material will be incorporated in the fuel supply. For example, traffic volumes and greenhouse gas emissions generated in the operation of the plant all assume that this fuel source is not utilised.

PLANTATION MANAGEMENT AND SUSTAINABILITY

The proposal would result in an improvement in forest management practices, reduction in insects/pathogens, increased mineralisation, improved regeneration through exposure of mineral soil, reduced costs of site clearing and re-establishment and expansion of forest based industry.

32, 34, 36

Noted. This statement is supported by the information provided by the contracted suppliers of biomass fuel. Refer to correspondence in Appendix B. The removal of residues following harvesting provides both an operational and financial benefit for the plantation owners and managers. The removal of plantation residues reduces the cost and increases the area available for replanting.

Plantation residues are a significant bushfire fuel, resulting in intense fast moving fires that are difficult to suppress, requiring heavy earthmoving equipment. If these fuels can be gathered up and taken away, they can be disposed of under controlled and safe conditions.

20, 32 Noted.

Utilisation of a resource that is currently not being utilised.

GS2, GS4, 1, 2, 8, 18, 55, 62

Noted. The use of the plantation waste for power generation provides a commercial option plus


PAGE 54

Provides for safe disposal of plantation waste.

reduced risks with regard to access (OSH) and fire hazard.

Claim that all plantation waste collected is burnt may not be true. The PER p25 implies all waste is burnt. However conversations with Blue Gum plantation owners suggests burning after harvest is not a common practice

17, 19, 31,

Correspondence from the contracted fuel suppliers indicates that the plantation waste to be supplied to the biomass plant would otherwise be burnt in the open. Refer to correspondence in Appendix B. When using the roadside harvest system whereby the trees are processed (stripped of bark, limbs and leaves) on a landing, the windrows of debris are burnt. The problems with leaving the material across the site are difficulty in physically preparing and replanting through the harvest debris, and just as importantly the material increases the fire hazard dramatically creating very dangerous conditions in which to try and control the fires. Some plantation operators undertake a cut-to-length process - mainly associated with coppice regeneration. The debris is retained through the plantation (i.e. not removed or burnt) which creates access issues and fire risk. The waste material from cut-to-length harvesting is not part of the contracted supply volumes from the suppliers to WA Biomass.

The Fuel Supply Section needs to be more accurately describe - the fuel requirements relative to

resource availability - projected fuel sources, harvesting

dates and plantation dates. - yields of waste per ha - sustainability of fuel supply for project

lifespan. No field tests have been reported by the proponents to lend an y credence to this process of biomass removal being cost effective or sustainable.

6, 17, 19

The details of the fuel supply contracts are assessed in the report by Fifth Estate is (refer Appendix A) demonstrating the sources, quantity and sustainability of supply for the life of the plant from plantation sources. This has included field tests. Each of the suppliers has undertaken trials to ensure the contracted supply is viable. The objective of the trials was to measure the dry weight of the biomass waste products that is generated during harvesting. There are significant fluctuations of total biomass within each of the sites but these trials have given an adequate degree of confidence in assuming that from the estate that each of the suppliers harvests there would be 45 - 50 tonnes/Ha of dry Biomass produced (as a conservative yield estimate). The suppliers are only able to contract fuel volumes on committed harvest planning cycles. Independent industry advice is that there is little risk of WA Biomass not being able to secure the necessary volume of biomass fuel from plantation sources on a sustainable basis for the life of the plant.

The Fuel Supply Section needs to be more accurately describe the plantation

10, 28, 31, 51 The removal of plantation waste from the plantations for use as fuel in the biomass plant is


PAGE 55

management and protecting the environment (soil and water protection). Potential for impacts on soil quality if less mulching/on-site decomposition taking place

not the primary purpose of plantation forestry industry. The plant is designed as a renewable energy project to reduce greenhouse gas emissions - to strike a balance between that amount of waste that can be used as fuel to generate electricity, while at the same time leaving some component of the waste that is required for plantation management and sustainability. A study by Yamada et.al. (2004) titled Biomass and Potential Nutrient Removal by Harvesting Short-rotation Plantations found that residue management in the plantation is important for nutrient conservation to reduce nutrient loss and help conserve site productivity. However, nutrient removal in stem (trunk) wood alone is substantial and considering the poor plant-available nutrient pool in the soil, the application of fertiliser is likely to be necessary in the industrial plantations where continuous high productivity is expected. The majority of the nutrients in the plantation waste left after removal of the trunk lies in the leaves, and for this reason the waste is left in-situ until the leaves and needles have fallen off. When using a roadside harvesting system it is all of the larger twig, branch and bark material as well as some of the leaves that are currently burnt and is now proposed to be removed for use in the biomass plant. The remainder of the leaves and some of the smaller twig material remains on site to decompose. The plantation suppliers believe that the introduction of a biomass market for plantation residues will coincide with an increase in use of roadside systems. The commercial option plus reduced access (OSH) and fire risks outweigh the nutritional benefits of retained residues which can be managed with alternative programs (fertiliser). The suppliers are of the view that such costs are much less than the benefits associated with having a biomass market.

Plantations must use land no longer suitable for agriculture for plantations, must be strictly monitored, to ensure minimum impacts from the plantations on the surrounding environment, waterways, fauna that may use the plantations as habitat, neighbours, etc.

65

While the removal of plantation waste from the plantations is not the primary purpose of plantation forestry industry, it is demonstrated in the contract requirements, as well as the correspondence from the major suppliers, that plantations are managed in accordance with a number of compliance systems, standards and codes of practice including: − Environmental Management System − Code of Practice for Timber Plantations in

WA − Timber Harvesting Manual (Plantations) − Standards of Practice as published by the

Forest Stewardship Council of Australian Forestry Standards


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The regimes required of the above systems and standards ensure minimum impacts from the plantations on the surrounding environment. It should be stressed that the proposal is based on harvesting the residue from existing and committed sources of supply. It does not rely upon the assumed development of new plantations to meet fuel supply requirements.

4.2 Land Use and Soils

The primary issues raised in submissions regarding impacts on land use and soils are the perceived adverse impacts that emissions will have on wineries, agriculture and food production in the vicinity of the plant. These issues were raised early in the consultation process and subsequently specific independent research and assessment of potential impacts was requested of both CSIRO Land and Water group and Smart Viticulture. Some submissions raised the additional issue of the relevance of the Food Strategy WA 2008. The Food Strategy WA: Building a healthy food future, Discussion Paper (February 2008) recognizes that the WA Food industry represents a significant part of the State’s economic activity, with a direct annual turnover for the food manufacturing sector of $5.5 billion and which employs about 9 per cent of the Western Australian workforce. World class farming systems and pristine marine environments enable Western Australia to produce meats, seafood, dairy, horticultural products, wines and grains which are in high demand in local, national and international markets. The paper notes that much needs to be done to ensure we maintain and enhance our food industry. The Discussion Paper notes that drought and climate change have become manifest through major impacts on productivity and food production in Australia. Rainfall trends show substantial decline in south west Australia since the 1950s, while the north west has experienced an increase in rainfall over this period. Recent climate simulations suggest there will be up to 20 per cent more drought months over most of Australia by 2030, with up to 80 per cent more droughts by 2070 in southern WA. There are two main points to take from this paper:

• climate change impacts on the south west, the main food producing region of WA, are forecast to be greater over the next 20 years with large scale implications for land and water usage as a consequence of drought and climate change. Proposed renewable energy sources, such as this biomass power plant, will result in an overall decrease in greenhouse gases being emitted in the region and will aid in the State meeting its renewable energy targets. Overall, the contribution of the plant to reducing climate change impacts is significant.

• prevailing food safety and quality assurance systems operating in Australia must respond to anticipated market requirements. To ensure the food products from the Manjimup region can continue to meet food safety and quality assurance requirements, the proponents must ensure that the proposed biomass plant will not impact on plants and agricultural crops in the surrounding area.

CSIRO Land and Water undertook a review of the potential effects of pollutants predicted to be emitted from the proposed biomass power station on plants and agricultural crops in the surrounding area (see Appendix C). This review concluded:

• hazards from particulates are likely to be low, and restricted to areas very close to the plant. • The predicted direct toxicity hazards from Sulphur Dioxide (SO2) emissions to plants and

crops were predicted to be negligible. • The predicted direct toxicity hazard from Nitrogen Dioxide (NO2) emissions to plants and

crops are predicted to be acceptable. • Acidification of soils due to deposition of SO2 and NO2 was predicted to be negligible.


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• The predicted direct toxicity hazards from emissions of dioxins/furans to agricultural crops were predicted to be negligible.

• Given the physicochemical behaviour of PAHs in soils, and the low increase in soil concentration due to power plant emissions, predicted direct toxicity to plants is unlikely.

• Predicted hazards posed by lifetime accumulation of inorganic contaminants in soil are small.

• Monitoring of emissions will be undertaken once the plant is operating to ensure predicted emissions are in line with actual emissions, and that actual emissions are within regulatory limits.

In response to the submission by Australian Wine Research Institute, which was echoed in many community submissions relating to the potential for tainting of wine, a report was undertaken on the possibility of air pollution from the biomass power station affecting neighbouring vineyards and wineries (Smart Viticulture, March 2008). This report is attached in Appendix D. The key findings of the report by Smart Viticulture are summarised as follows:

• An analysis for guaiacol is considered sufficient to represent all compounds (many are chemically related to guaiacol) which are known wine taints from wood smoke. The concentration of guaiacol during the Victorian Bushfire event corresponded to an accumulation of guaiacol in grapes of up to 45µg/kg in cabernet sauvignon grapes. Given the relationship between guaiacol concentrations in air and the corresponding accumulation in grapes, the predicted concentration in grapes with background guaiacols levels in Manjimup is 9µg/kg. The taste threshold of detection in grapes is published to be 5.7 µg/kg (Krstic and Whiting, 2007), while some wineries typically do not process grapes with concentrations between 2-6µg/kg. Given taints are not apparent in wines produced in this region for the most recent vintages with the predicted level of guaiacol in grapes indicates that there is a threshold concentration of guaiacol in air before which accumulation of this compound in grapes is reduced. This is indicative of a non-linear relationship between the rate of accumulation of guaiacol in grapes and the concentration of guaiacol in air. Taints are not apparent despite background variation of up to 50% in PM2.5 concentrations in air monitored in Manjimup. Background concentration of PM2.5 considers sources other than biomass burning, hence the predicted concentrations of guaiacol are extremely conservative. Given this uncertainty, measuring guaiacol concentrations in grapes concurrent with ambient air concentrations of PM2.5 in vineyard is recommended.

• When vineyards have been contaminated by bushfire smoke, the bushfire smoke is present

for an extended period in the vineyards. Visibility is often less than 1 km. Minimum visibility of less than 1.0 km was associated with PM 10 values of over 200 ug/m3. Further, good visibility of 20 km is associated with PM10 value of 50 ug/m3; both are stated air quality objectives. It can be seen that reduced visibility of <1km and associated PM10 value of >200 µg/m3 is considerably in excess of daily values predicted for PM 10 concentrations around the proposed power station. The highest values shown are 0.76 µg/m3. Therefore smoke should not be visible on the ground originating from the biomass plant stack. This further supports the point of view that vineyards which are at their closest 3.3 km from the proposed smokestack will not be contaminated by guaiacol and related compounds emitted from the site.

• Vineyards have a sensory threshold in the “low µg/L range”, conservatively assumed as 1 µg/L, for polycyclic aromatic hydrocarbons (PAH). Based on the atmospheric values being about 6 orders of magnitude (1/1,000,000) less than the sensory threshold in wine, it is unlikely that PAH emissions will impact on grapes or wine. This conclusion is supported by comparing the current level of PAHs emitted in the Shire of Manjimup, noted by Coulter as 3,115kg/annum, compared with that from the proposed power station of 74kg/annum.. .


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• The sensory threshold value in wine for chlorophenols was determined by AWRI

experiments. For the 8 congeners investigated in a Chenin Blanc white wine, the panel averaged best estimate threshold varied from 32 to greater than 296 ng/l. The cumulative daily averaged exposure for grapevines from likely worst case emissions from the biomass power station is predicted to be 0.0023pg per litre. This one hundredth thousandth of the sensory threshold stated. While no information is available on the extent to which chlorophenols may be absorbed and concentrated in the juice of the grape, and perhaps during fermentation, such a bio-concentration effect seems most unlikely, if not impossible.

• Based on the analyses, there is no evidence to suggest that atmospheric emissions from

the proposed biomass power station will cause any taint of wine in neighbouring vineyards and wine. The predicted atmospheric values of guaiacol, PAH and chlorophenols are so low as to be orders of magnitude lower than threshold sensory concentrations in wine.

Numerous submissions were also received detailing the advantages associated with the proposed site location. The primary advantages were that the proposed site is already an industrial area, it is close to a power substation and there is existing infrastructure on site with existing suitable buffers in place The issues and statements received regarding the impact of the biomass plant on local land-use and soils in the area surrounding the plant are addressed below. Table 4-2 Land Use and Soils Issues & Statements


Response

IMPACT ON VITICULTURE, HORTICULTURE AND AGRICULTURE

Concerns that emissions will taint grapes and impact on wine production.

3, 6, 12, 13, 17, 19, 23, 26, 28, 30, 41, 42, 53

Based on the analyses, there is no evidence to suggest that atmospheric emissions from the proposed biomass power station will cause any taint of wine in neighbouring vineyards and wine. This assessment is undertaken in the Smart Viticulture report, refer Attachment D.

Similar plants exist elsewhere in Australia and the world and operate close to large populations and food production areas without any apparent harm to people or the environment.

33 Noted.

PAH's are able to taint wine and render it unsaleable in concentrations as low as 1 part per trillion. Increased exposure of the vineyards to PAH's may increase the risk of any background level of PAH's exceeding the sensory threshold in the wine.

41

Vineyards have a sensory threshold in the “low ug/L range”, conservatively assumed as 1 ug/L, for polycyclic aromatic hydrocarbons (PAH). The annually averaged maximum concentration for PAH near the proposed power station is 0.00000099ug/L. This is one-millionth the sensory threshold stated above. Based on the atmospheric values being about 6 orders of magnitude less than the sensory threshold in wine, it is unlikely that PAH emissions will impact on grapes or wine. This assessment is undertaken in the Smart Viticulture report, refer Attachment D.

The best wines are usually produced from 80 to 100yr old vines. Emitting pollution over a 25 yr period is a serious threat to the long-term goals of the wineries. The impacts of placing a major source of serious pollutants in close

41

Smart Viticulture was engaged to assess the impact on viticulture and was provided with research material on smoke taint from recent severe bushfires in Victoria, and current research outcomes from Curtin University’s investigations into effects of prescribed burning on wine taint.


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proximity to vineyards and wineries is of concern.

Ground level concentrations of compounds considered most likely to taint wine (ie. Guaiacol, 4-methyl guaiacol, PAH’s, chlorophenols etc) were predicted and compared with thresholds known to taint wine. On a cumulative basis (assuming grapes/vines completely absorb these concentrations continuously), it was determined that concentrations attributed to the power station were several orders of magnitude less than the threshold, and therefore unlikely to taint wine. This outcome is substantiated as current ambient air pollutant concentrations are about 4 times greater than the predicted power station emissions, and given this level of pollution does not currently cause taints. In addition, a survey of biomass power stations located in wine regions throughout Europe and North America provides further justification that wines will not be tainted by emissions from the power station.

- Direct and indirect impacts (of air quality) on food production and agriculture. - Build up of particulates will affect growth, diseases and pest resistance of the trees and plants based in orchards, vineyards and truffleries around Manjimup. - Short or long term effects of emissions such as ozone, sulphur dioxide, together with lead and dioxin, which can contaminate fruit and vegetable crops and enter the food chain. - Recommend that EPA determine distance from plant where food production can be carried out safely. - Damage to forests. Potential damage to the health of the Diamond Tree

GS1, 3, 6, 11, 12, 13, 14, 19, 28, 42, 26, 41, 48, 50, 47, 31, 64, 65,

Investigation has demonstrated that hazards posed by lifetime accumulation due to emissions from the biomass power plant are small. Direct toxicity hazards from emissions to plants and crops are predicted to be acceptable, if not negligible. This assessment is undertaken by CSIRO Land and Water, refer Attachment C. Based on this assessment it is considered that food production can be carried out safely in the Rural areas surrounding the site.

With respect to smoke emissions on vineyards, it must be remembered that not so long ago several sawmills operated in the area which burnt mill waste in open fires 24 hours a day, 12 months of the year. Deanmill and Pemberton Mill were very close to housing and burnt non stop for over 50 years. In addition every home had a wood stove in the kitchen and an open fire in the lounge room. In the Hunter Valley in NSW there are several very large coal burning power stations which has not apparently affected the regions reputation as one of the famous wine producing centres in Australia.

1 Noted

Emissions from trucks likely to increase background levels of VOC's and PAH's in vineyards close to transport routes

41

The percentage increase in vehicle movements is low and would not be a significant contributor to air quality impacts on road side vineyards. The report by Smart Viticulture on the possibility


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of air pollution from the biomass power plant affecting neighbouring vineyards (refer Appendix D) refers to only one known case where vineyards beside the New York State Expressway were known to be affected by lead emissions from motor cars. With a reduction in the use of leaded fuels this ceased to be a problem. In this case very high traffic volumes were experienced on the Expressway. The only road where significant traffic volumes are currently experienced is the South Western Highway. The expected increase in traffic volumes on the South Western Highway due to the biomass power plant is between 1.1 and 4.4%.

SOILS

Geology and soils - Description is not indicative of site.

17

The description of geology and soils was sourced through the available information from the Department of Agriculture and Food, based on the Soils and Landforms map of the Manjimup Area by H.M. Churchward, 1992. A detailed geotechnical assessment of the site has since been undertaken and CSIRO Land and Water has reviewed the available information to assess the potential for impact on soils (see Appendix C).

The soils in the region are very old and shallow at the tops of the hills. Areas where loaders and trucks are operating need to be built up with gravel and shale to reduce the amount of bogging and reduction in soil structure.

GS3

Noted. The post-harvest chipping and retrieval processes for processing and transporting the plantation waste are mostly done at the roadside, thereby reducing the impacts on soil structure within the plantation. However, management measures would be applied as appropriate for in field operations.

What will be the cumulative effect of 20 tonnes of lead on soils, waterways, orchards, and vegetable plots over a 25 year period. There is a need for soil testing.

17, 30, 41, 50

The assessment is undertaken by CSIRO Land and Water (refer Appendix C) found that, for inorganic compounds including Lead, predicted hazards posed by lifetime accumulation in soil due to emissions from the biomass power plant are small and are well below acceptable levels or “predicted no-effect concentrations” derived from regulatory benchmarks. Hazards from these elements are likely to be low due to the small predicted accumulation of contaminant in relation to ambient background concentrations.

SITE LOCATION

A more comprehensive report on site selection should have been provided.

54

A whole range of commercial, environmental and community impact considerations are involved in selecting a site including: proximity to a suitable connection to the SWIS (the power input to the grid is required to step up to 132kV); centralised locality for fuel (plantation waste) volumes to be supplied from a maximum radius of 100km; land tenure and existing use; Land area; Suitable road access; and manageable site and environmental impacts. A number of sites were identified and reviewed


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against the criteria for their suitability. This process was reported in the PER. It is accepted that any site will have relative merits or disadvantages but is designed to narrow the selection to one site that can then be comprehensively assessed in terms of specific impacts. The PER assessment process is to ensure that the community and regulators can determine whether it is a suitable site based on the potential impacts.

The proposed site is a suitable location as it is an underutilised brownfields site which is already an industrial area, close to substation, existing infrastructure (including an operating weighbridge), and existing buffers.

GS2, GS3, GS4, 49, 39, 37, 18, 55, 58, 8,

Noted. The site meets the site selection criteria described above.

Why could the project not be sited within one of the forest blocks central to the majority of the plantation forest blocks. Is it that the costs to connect this to the grid make the project unviable versus the reduction in transport costs?

17 The site is central to an area of State Forest which provides an excellent buffer to surrounding Rural land. See also response above.

Based on World Health Organisation Best Practices for Incineration, the project should not proceed in this location due to the very high risk to public health, the food chain and the environment.

6

The WHO goals are met by this location in the following ways: - ambient air concentrations, deposition of pollutants to soils foods etc are minimised by the use of an efficient combustion system and best practice air filtration.

- While the site is within a forested area, a stack is used to ensure optimum dispersion of emissions. The site is on a ridgeline, further optimising dispersion, and the surrounding forest provides a visual amenity buffer.

- The study undertaken by CSIRO Land and Water (Appendix C) has demonstrated that the potential for impact on agriculture nearby is negligible or acceptable.

-

Give priority attention to the pre-existing interests of 'traditional' rural land use and users.

48, 64, 65,

This is a regional land use planning issue that is dealt with by the Shire Council through its Town Planning Scheme and the DEC in managing its forest estate and Crown Land reserves when considering the location of timber plantations.

If necessary because of air pollution, the plant should be approved for a lower generation capacity (perhaps 20MW, rather than 40MW) and relocated to the Manjimup Industrial Park. A trial period of 5 years has been suggested.

17, 47, 48, 64, 65,

The Air Quality assessment and Health Risk Assessment have demonstrated that the site is suitable from an air quality perspective. The suggestion of a 20MW power plant in the Industrial Park is not suitable for the followings reasons: - a commercial agreement is in place with

Synergy for the supply of 40MW of power into the SWIS.

- the Industrial Park is closer to the township of Manjimup and does not afford access to the power grid without extensive infrastructure provision which would, in itself, have impacts on the amenity of the area.


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Damage to ambience of the area and effect on property prices.

3, 12

The site offers excellent buffers to surrounding Rural areas which the proponent considers will result in little impact on the Rural ambience of the area. The plant and equipment will only be slightly visible from public roads, and private land, and compliance with EPA Regulations with regard to noise and other operational requirements will ensure that there is minimal impact to neighbouring residents.

The plant should be located in the Albany region to take advantage of the huge, spatially concentrated plantation bluegum resource in that region and to provide power for Albany.

66

It is acknowledged that there may be potential for a biomass power plant in Albany to take advantage of the plantation resource in that region. It has been demonstrated that a similar plantation resource exists in the Manjimup region to adequately service a 40MW biomass power plant at this site also.


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4.3 Visual Impact

Very few issues were raised concerning the visual impact of the plant on the local environment. This is considered to be due to location of the plant (the existing state forest creates a strong visual buffer) and also due to the mitigation measures being proposed to minimise its visual impact (i.e. painting the stack ‘pale grey’ and external buildings and plant equipment ‘mist green’). The Heritage Council of WA have stated that in order to fully assess the impact of the proposed 40m high stack a photomontage should be developed to clearly illustrate what the view to the proposed stack from the Diamond Tree will be. It should be noted that the existing WAPRES timber mill exists between Diamond Tree lookout and the proposed site (PER Section 8.4). The tallest element of the mill is the woodchip conveyor, which is barely visible through the screen of trees from the Diamond Tree lookout as demonstrated in Photograph 1. Vegetation screening of 35 – 40m high exists to the left (south west) of the conveyor, which is approximately where the plant and equipment (including the stack) would be located. It is considered that a photomontage is not possible as the plant would not be recognisable through the vegetation screening when viewed from the Diamond Tree lookout.

Photograph 1 – View from Diamond Tree lookout to the Diamond Mill: The Mill conveyor is circled.

The two existing communications towers, standing at an estimated 80 – 100m tall, are equally as close to the Diamond Tree and do not have the benefit of a forestry barrier to assist in screening them from view from the Diamond Tree viewing platform as demonstrated in Photograph 2, taken from Diamond Tree lookout. However, while they are large structures that are not coloured to blend with the environment, the towers appear insignificant in the panorama.


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Photograph 2 – View from Diamond Tree lookout to the existing towers (circled)

The tower that exists at the power substation is twice as close to the Diamond Tree than the Mill site, and is 20% larger than the proposed plant equipment. It is not afforded good vegetation screening. It is a visible vertical structure on the horizon.

Photograph 3 – View from Diamond Tree lookout to the existing 50m substation tower (circled)


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Table 4-3 Visual Issues & Statements


Response

Additional light at night 12 The large lot sizes of the properties adjacent to the State Forest, the location of houses relative to property boundaries, limited direct lines of site and large distances from the plant site indicates there should be negligible light overspill from the project. The plant, where elevated light sources are most likely, is 1400 metres from the nearest house. The stack, the tallest part of the infrastructure, will not require aircraft warning lights and other operational lighting requirements will be designed to ensure there is no off-site light spill. No significant adverse impacts are anticipated.

Visual impact of the site on Eastbourne Road (State Tourist Drive 259).

23 The development site is accessed via Palings Road, off Eastbourne Road. It is set well back from Eastbourne Road and significant vegetation screening exists in order to protect visual amenity from the road. The area of land between Eastbourne Road and the development site is State Forest.

Visual modelling and impact from Diamond Tree Lookout.

23, 53, 67 Visual assessment (based on topography, heights of vertical elements, and distance) shows that visual impact from the Diamond Tree lookout will be minimal as significant vegetation screening exists between Diamond tree and the proposed development. The minimal impact has been demonstrated visually above.

Potential impacts on visitors when the smoke emissions are directed towards Diamond Tree needs to be taken into account.

51 The will be no visible smoke plume from the stack

Visual impact of stack will be less than current smoke from bark dump

GS3, Noted. This is considered to be correct. The PER (Section 8) demonstrated that the visual impact from smoke generated at the bark dump causes significant visual hazard on Channybearup Road. As noted above, the biomass plant will produce no visible smoke plume due to the efficient emission filtration process used.

The proponent needs to liaise with DEC's Warren Region, to ascertain more detail on the logging program proposed for the surrounding State forest and the potential need for additional screening by the proponent.

51 The proponent commits to preparing a detailed landscaping plan based on consultation with the DEC's Warren Region, to demonstrate requirements for additional screening to address local visual impact in the potential case that the surrounding State forest is logged resulting in impacts on visual amenity. This plan will be provided to the Shire Council with the detailed design of the proposal.

4.4 Greenhouse Gas Emissions

The Government's Mandatory Renewable Energy Target commenced on 1 April 2001. The Renewable Energy (Electricity) Act 2000 currently requires the generation of 9,500 gigawatt hours of extra renewable electricity per year by 2010, enough power to meet the residential electricity needs of four million people.


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The two main issues received regarding Greenhouse Gas Emissions (GGE) are whether the GGE emissions associated with the transport of the fuel were included in the modelling, and that the plant would increase carbon dioxide emissions in the local region. Submissions were also received highlighting that the proposed plant will result in an overall decrease in greenhouse gases being emitted and will aid in the State meeting its renewable energy targets. Generation of electricity from the combustion of plantation residues is a low emissions form of electricity generation in terms the contribution to the greenhouse effect. This is due to the carbon originating from a renewable resource that draws carbon from the cycle of exchange between biomass and the atmosphere. In contrast, much of the existing electricity generation for the SWIS utilises finite resources of fossil fuel which following combustion contributes to increased carbon dioxide levels in the atmosphere. Where the biomass fuelled generation displaces fossil fuelled generation (such as coal in this case), savings in greenhouse gas emissions accrue. The assessment of the greenhouse gas emissions associated with the Biomass Power Plant has considered the various sub-elements of the project including construction, fuel supply and power generation and where relevant applied specific Australian Greenhouse Office (AGO) emission factors to the estimation of greenhouse gas emissions. Overall the assessment has found that there is a positive greenhouse benefit by using biomass to generate electricity relative to the existing generation for the SWIS. This is primarily delivered through low emissions for the power generation process together with displacement of potential emissions from fossil fuel sources associated with electricity generation supplied into the SWIS. The biomass fuelled Power Plant also appears to satisfy the requirements for eligibility as an accredited renewable energy Power Plant that is able to create Renewable Energy Certificates (RECs). To claim RECs the operation must be eligible for RECs from an eligible fuel source. Only accredited renewable energy power stations are eligible to claim RECs. Table 4-4 Greenhouse Gas Emissions Issues & Statements


Response

The plant will produce 1.2T CO2/MWh versus coal at 0.92T CO2/MWh. Thus as a plant it is physically worse than coal before the carbon credits are applied. The PER is misleading as the use of plantation biomass assumed carbon emissions savings, where carbon held within plantation residues may initially be relatively locked up, releasing carbon only very slowly over many years within its decay process. Through manipulating the rate of carbon exchange the proponents have claimed the biomass plant to be environmentally beneficial and carbon neutral. It will increase output of greenhouse gases produced

17, 19, 31

Generation of electricity from the combustion of plantation residues is a low emissions form of electricity generation. This is due to the carbon originating from a renewable resource that draws carbon from the cycle of exchange between biomass and the atmosphere. The greenhouse gases released into the atmosphere from operation of the biomass plant will remain the same as they currently are on the assumption that this fuel already contributes emissions to the atmosphere from being burnt in the field for plantation management purposes. This process would also occur if organic material were allowed to decompose rather than being burnt. Much of the existing electricity generation for the SWIS utilises finite resources of fossil fuel which, following combustion, contributes to increased carbon dioxide levels in the atmosphere (the greenhouse gases from fossil fuels would otherwise not be released into the atmosphere). The biomass power plant captures the energy value from the biomass fuel, displacing fossil fuelled generation (such as coal in this case), and savings in greenhouse gas emissions accrue.


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within the region. The Greenhouse Gas Assessment in the PER is neither misleading nor manipulative. The assessment has been undertaken in accordance with the WA EPA’s Guideline for Assessment of Environmental Factors, specifically the Guidance Statement for Minimising Greenhouse Gas Emissions No.12.

An Australian Bureau of Agricultural and Resource Economics (2007) report suggests a massive decline in farm production and agricultural export earnings in coming decades unless we can halt climate change. This underscores the need to strengthen rural communities to help with the battle against climate change.

43 Noted.

Increases use of renewable energy and will help meet State requirement to meet renewable energy targets

8, 9, 18, 33, 37, 34, 43,

Noted, see above.

Will reduce Greenhouse Emissions

8, 40, 38, Noted, see above.

Climate change predictions not included

27,

Projections of future changes in climate were discussed in Section 10.2.5 of the PER. Renewable energy is reducing the potential for climate change by reducing the level of global emissions. Many sources report that the effets of climate change could have catastrophic consequence on the agricultural industry in Australia, including that in Manjimup and the South West region. Climate change is also predicted to produce more frequent and intense bush fire events, with their attendant threats to homes, lives and agriculture.

Have transportation emissions been included in GGE modelling

12, 16, 53 The PER does take into account greenhouse gas associated with trucks and fuel transport – See Section 10.9 of the PER.

Site has moved south 50km from Bridgetown but supplies still within 100km?

6

Justification of average round trip of 130km

52

Significant investigation has been undertaken by the proponent with the four major suppliers of plantation waste to the proposed power plant including review of the proposed fuel supply, the capacity of the suppliers to harvest, gather, collect and transport the wood and forest based fuels, and the reasonableness and sustainability of the supply agreements. Each of the suppliers has reviewed the plantation sources within the collection radius in relation to the proposed site at Diamond Mill and committed to supply of plantation waste within the distance criteria. A thorough recent review of the biomass fuel supply has been undertaken including analysis of: - Harvest location - Plantation size, tonnes per hectare, and resultant tonnage - Haul distance The summary of average haulage distances is

Est Average Haul Distance


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WAPRES 75

GSP 70

ITC 70

WAFPC 95

Combined 77.5

Average Round Trip = 155 On this basis the Greenhouse Gas Emissions associated with the transport of biomass is 2407.97 tCO2-e. This is a difference of 388 tCO2-e per annum. The resultant net greenhouse benefit of the Biomass Power Plant relative to the existing SWIS generation is -260,891 tonnes CO2 equivalent per year, and is still a lifetime saving of more than 6.5 million tonnes CO2 equivalent. Other opportunities such as the use of plantation based Mill waste and backloading of trucks, have not been factored into the Greenhouse Emissions accounting. On this basis it is considered that the assessment provides a conservative result.

The PER has used the combustion factor for electricity on SWIS of 0.871 kg CO2/kWh rather than the full fuel cycle emissions factor of 0.98 kg CO2/kWh. This underestimates the GHG savings.

54 Noted. The PER has used 0.871kg as the SWIS is heavily gas generated. The emissions factor used is also linked to the combustion cycle for renewable energy.

Oxides of nitrogen are also greenhouse gases and have not been taken into account

48

The AGO has developed factors that take account of the renewable nature of the biomass energy source which derives carbon from the cycle of carbon between the atmosphere and biomass. There are CO2 and non-CO2 contrubutions to this cycle. The non-CO2 contributions, as outlined within the AGO factors, include: CH4, N2O, CO, NOx, NMVOC and SO2. These non CO2 contributions, which include oxides of nitrogen have been considered and are outlined in Table 10.10 in the PER document.


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4.5 Air Quality

Numerous issues, statements and recommendations were received regarding the impact that the proposed plant would have on the Air Quality of the surrounding environment. The Shire of Manjimup also engaged Sinclair Knight Mertz (SKM) to carry out an independent review, while the proponent engaged Katestone Environmental to carry out an independent review. Both reviews recommended testing the findings in the PER using alternative methodologies, and in response, a revised air quality assessment, addressing all issues, has been prepared and is attached as Appendix E(a). The findings of the review conducted by Katestone Environmental are provided in correspondence attached in Appendix E(b). Reassuringly, the original approach taken for the PER was more conservative (ie. suggested greater impact), than results using alternative methodologies. The following summarises the issues raised in these reviews:

− Use of Bunbury ambient air quality data in place of that for Manjimup

The use of one year of background air quality monitoring data is recommended by the DEC. On commencement of the air quality assessments the DEC Manjimup office advised that no such data existed for the region. In mid 2007, background air quality monitoring was carried out by the proponent in Bridgetown. To satisfy the DEC’s requirement for one year of monitoring data to be used in the assessment, the results of the Bridgetown monitoring were compared with monitoring over the same period in Bunbury. It was concluded that Bunbury presented worst case ambient (or background) air pollutant levels for Manjimup. Despite this conservative approach there has been some criticism of the use of this data. During the PER process, it was discovered that the CSIRO (for the Commonwealth Department of Environment and Heritage) had been monitoring air quality in Manjimup from 2006 to 2007. We have since sought and received this data for validation of local conditions. This data has been compared statistically with data from Bunbury, with Bunbury data found to be higher or at least comparable with that in Manjimup. That is, use of the Manjimup data generally increases the safety margin with regards to the assessment criteria. Similarly the inclusion of background data for NO2, by simply adding the maximum concentration from Rolling Green (considered to provide a conservative estimate of NO2 given its rural location relative to Perth) has been criticised. It was recognized that an alternative approach would be to include into TAPM, background concentrations (of VOCs and NOx) on a grid basis, and to run TAPM in photochemistry mode. Biogenic and anthropogenic emissions of NOx and VOCs have been included on a grid basis in TAPM using photochemistry mode (GRS). Anthropogenic emissions have been included on the inner most grid, while biogenic emissions have been included on the second most outer grid. These emissions have been applied based on the emissions listed in the NPI report for the Shire. Point source emissions from nearby major industrial sources (ie. Muja and Collie power stations) were also included (based on data acquired from the Bluewaters Power Station assessment). Background NO2 concentrations were compared with monitoring results for Bridgetown. The use of this approach represents a considerable reduction in cumulative emissions than the approach used in the PER, demonstrating that the impact on the environment from NO2 emissions will be even less than previously estimated.

− Inclusion of air quality data into TAPM leading to unusual gridded cumulative emissions

Background concentrations of particulates were included in the run-time simulation, by applying background data to the outer grid (inflow boundary) of TAPM. This data was applied in consultation with the CSIRO, who were also consulted given the outcome of “dispersion” of background data to other grids. Given the unusual gridded concentrations of background data calculated by TAPM, it was decided to apply background data as a post processing task. This


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has resulted in a marginal reduction of the cumulative level in comparison with the results from the PER.

− Modelling of oxides of nitrogen using the photochemical reaction set provided by

TAPM, and assumptions regarding background concentrations (biogenic and anthropogenic emissions) of ozone, nitrogen oxides and volatile organic compounds (VOC’s).

It is recognized that VOC’s, NOx and O3 react photochemically to influence the concentration of each pollutant on a diurnal basis. TAPM was therefore run using photochemistry mode (that is using the Generic Reaction Set, GRS). In consultation with CSIRO, a conservative “background level” of VOC’s was included, but specific biogenic/anthropogenic emissions of NOx and VOC’s were not included. Additionally, the reaction set is NOx limited, that is, an unlimited supply of VOC’s would be unable to react to form NO2 without the supply of NOx. Specific biogenic and anthropogenic emissions of VOC’s have been included on a grid basis as an input to TAPM. VOC’s emitted by the proposed power station were also included (as “in-plume” emissions). The accuracy of TAPM’s in photochemistry reaction set (GRS mode) was verified by modeling NO2 ground level concentrations using:

− tracer mode (without chemistry), where all of NOx is assumed to be NO2 and dispersed without reacting with other compounds

− the ozone limiting method (OLM), where 10% of NOx is assumed to be NO2, and the ground level concentration is calculated from the dispersed level of NO2, the background level of Ozone, and the background level of NO2 (calculated from biogenic and anthropogenic emissions of NO2 and VOC’s).

− chemistry mode (GRS) with biogenic and anthropogenic area/point sources,

A comparison of the various methods shows that chemistry mode results are similar to results using the OLM method, with both about 25% of the results using tracer mode. This is consistent with the expected concentration of NO2 from previous studies comparing measured stack emissions with measured ground level concentrations. The outcome is that predictions of NO2 concentrations in the PER (by a simple linear addition of the background NO2 concentration in a region affected by the Perth airshed) are considerably higher (about 40%) than the estimates using the method described above. That is, the power station has even less impact on the environment than predicted in the PER.

− Detailed consideration of “other” pollutants (PCDD/F’s, PAH’s, trace elements)

The Stockholm Convention for Persistent Organic Pollutants (POP’s) notes that for biomass-fired plants, particularly wood-fired installations, emission levels of persistent organic pollutants associated with best available techniques are generally below 0.1 ng I-TEQ/Nm3. Among the primary measures, control of fuel quality is a key issue (including exclusion of treated wood), with best practice considered to be the use of a bubbling fluidised bed boiler for optimal combustion, and a baghouse to provide a proven and reliable method for pollutant extraction. The concentration of POP’s from the proposed biomass power station is predicted to be 0.038 ng I-TEQ/dscm (dscm – dry standard cubic metre), and therefore complies with the recommended level. This claim is further verified by the IPPC; “In some biomass fired plants, especially wood-fired combustion plants, the emissions of dioxins and furans have been measured and an emission level of below 0.1 ng/Nm3 is generally regarded as achievable.” A more detailed description of POP’s is included in section 4 (Assessment Criteria) and section 9.2 (Modelling Results and Impact Assessment) of the Air Quality Assessment attached as Appendix E(a).


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In summary, the predicted emissions of POP’s are well within internationally accepted limits.

− Controlled versus Uncontrolled emissions of pollutants

The PER included controlled (through extraction of pollutants via the baghouse filter) and uncontrolled emissions of “other” pollutants. This was because emissions control was not considered necessary to comply with the criteria. The revised air quality assessment includes controlled emissions, that is reductions provided by the baghouse filters, of “other” pollutants, which are now even further below the assessment criteria.

− Comparison with Best Available Technology (as provided by the IPPC, within the European Commission)

The choice of a fluidised bed combustion boiler and baghouse are technologies that are considered best practice based on the Integrated Pollution Prevention and Control (IPPC), Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006). The use of an electrostatic precipitator (ESP), as originally proposed for the Bridgetown site, is less efficient at extracting pollutants than the baghouse. It has been claimed that wet scrubbers were to be used at Bridgetown, however this has been confused with cooling towers which serve an entirely different purpose (condensing the steam from the turbine). Wet scrubbers are not required to control emissions, and have not been considered here.

− Comparative Studies – prescribed burning vs biomass power plant

The following section has been included in the Air Quality Assessment:

The discussion above compares worst case ground level concentrations of particulates between emissions from the proposed biomass power station with those from prescribed burning. An alternative means of comparison is to consider annual emissions themselves, rather than the resulting ground level concentrations. This has been done in part, and reported in Table 8.1, with regard to annual emissions from the proposed biomass power station. Table 4.5 includes annual emissions for prescribed burning (as estimated using the NPI emissions factors for prescribed burning) for PM10 and PM2.5 (with PM2.5 estimated as 80% of PM10 emissions). The reduced emissions from efficient combustion in the biomass power station is clearly apparent.

Table 4.5 Annual emissions of particulates for comparison of prescribed burning to biomass power station combustion

Sources Pollutant

(kg/yr) Biomass Power Plant

Prescribed Burning

PM10 56,700 4,560,000 PM2.5 45,360 3,648,000

− Accuracy of TAPM at predicting meteorology

The DEC requested a comparison of Bureau of Meteorology (BOM) 3am data, which (as verified by the DEC) was not available for the chosen year (2001). It was also assumed that the BOM data acquired (hourly for other times) was measured at 10m, however as noted by the DEC, the BOM changed from ground level observations prior to October 2000, to 30m mast measurements (although long term BOM data is effectively at 10m).


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A comprehensive comparison of TAPM predicted meteorology with 2002 BOM measured meteorology was carried out by considering wind roses on a seasonal and annual basis, and diurnal basis. Wind class frequency distribution was also considered on a diurnal and annual basis. Correlation between predicted and measured wind direction and speed are relatively good, though TAPM does under predict the frequency of low wind speeds during nighttime. Notwithstanding this, there is a sufficient frequency of low wind speeds and direction to ensure an adequate level of conservatism of predicted ground level pollutant concentrations. Additionally, given the source of emissions is at 40m, and following discussions with the DEC in early 2007 regarding this issue, alternative prediction models such as Calpuff were not considered necessary.

− Greater definition of monitoring requirements

The key elements of the air quality management plan include: − Baseline monitoring of ambient air pollutant concentrations prior to operation, together

with meteorological monitoring at a fixed location. Baseline monitoring will be carried out at a nominal 3 sensitive receptors around the plant. Monitoring will be carried out for a minimum period of 12 months

− Ongoing monitoring during operation of the plant at sensitive receptors, together with real time in-stack monitoring

− Monitoring will include but not be limited to criteria pollutants (NO2, SO2, CO, O3, Pb, PM10, PM2.5 etc) and air toxic pollutants (PAH, PCDD/F, Trace Elements)

− Emissions control technology will be constantly monitored by measuring the pressure across each bag filter. Should the pressure noticeably increase/decrease from a prescribed range, that section of the baghouse will be immediately shutdown and flue gas immediately bypassed to the standby section. If both sections fail, the plant will be immediately shutdown.

− Routine fuel sampling will ensure the correct mix of fuel is maintained, and that the fuel does not contain any hazardous compounds such as insecticides.

− Air quality monitoring results will be used to rerun the air quality model to verify its accuracy.

− Ash will be routinely sampled to determine its suitability for a specific landfill classification

The main submissions received outlining the benefits on the Biomass plant in regards to air quality is that the plant will improve existing air quality and will also reduce the occurrence of uncontrolled burning in the area. Table 4-6 Air Quality Issues & Statements


Response

AIR QUALITY CRITERIA

Air Toxics NEPM not cited 53 The Air Toxics NEPM is a guideline, and reflected in assessment criteria published by the NSW EPA. It has been included (along with other international standards) in the revised air quality assessment, attached as Appendix E(a).

Pollutant concentrations will exceed rural parameters in vicinity of the plant

14

The ambient air national environment protection measure (NEPM) provides criteria that ensure the impact on human health and the environment will be acceptable. The air quality assessment has demonstrated compliance with these limits with the inclusion of the already high background concentrations of pollutants (mainly particulates) already in the environment. The CSIRO were commissioned to assess in detail the likely effects of pollutants on agriculture, concluding that risks


PAGE 73

on agriculture were acceptable.

Dioxin production needs to take into account Stockholm convention and National Dioxins Programme

6,19

The Stockholm Convention for Persistent Organic Pollutants (POP’s) notes that for biomass-fired plants, particularly wood-fired installations, emission levels of persistent organic pollutants associated with best available techniques are generally below 0.1 ng I-TEQ/Nm3. Among the primary measures, control of fuel quality is a key issue (including exclusion of treated wood). Control measures for non-contaminated biomass include optimized combustion techniques and dust removal. The use of a bubbling fluidised bed boiler provides optimal combustion, while the baghouse provides a proven and reliable method for pollutant extraction. The concentration of POP’s from the proposed biomass power station (0.038 ng I-TEQ/dscm) complies with the recommended level. This claim is further verified by the IPPC; “In some biomass fired plants, especially wood-fired combustion plants, the emissions of dioxins and furans have been measured and an emission level of below 0.1 ng/Nm3 is generally regarded as achievable.”

International study stating that burning the plantation waste in a controlled environment can reduce emissions by 96% was not referenced in the PER.

12,

A major contributor to poor air quality and reduced visibility in the Central Valley of California is open-field burning of agricultural crop residues. Burning in this manner produces significant amounts of major air pollutants that have been linked to numerous health related problems. Biomass-to-energy power plants have been shown to reduce emissions from agricultural wood wastes by 96.5 percent as compared to emissions that would occur if those same wastes were burned in the open field. "Emission Benefit From Firing Orchard Residue at Delano Energy Company", Dr. C. Moyer and J. Pont, Acurex Environmental Corp., December, 1997 http://www.calbiomass.org/technical8.htm This is considered in the revised air quality assessment, which compares emissions from burning plantation waste in a controlled environment (high temperature boiler with a bubbling fluidised bed providing highly efficient combustion, a baghouse filter removing pollutants from the flue gas, and the flue gas being exhausted at a high level/velocity) to open burning. It concludes that ground level concentrations of pollutants from the biomass power station are almost two orders of magnitude less than those from open burning (eg. PM2.5 ground level concentrations from the Biomass Power Station are about 3 µg/m3, while from open burning they are about 83 µg/m3). Refer to the revised air quality report attached as Appendix E(a). This has been verified independently by the SKM review.


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Comparison and use of European Commission Guidelines The statement "EC goals are considered more restrictive due to the density of the population…" in paragraph 2, p128 is inaccurate for dust and Nox emissions. Goals of 30mg/Nm3 for dust and 300mg/Nm3 for Nox for new plants should apply.

EPA, 52

The equipment vendor, RCR Technologies, confirmed the following emission guarantees with Babcock and Brown: The emission of particulates will not exceed 30mg/Nm3 for dust at 100% MCR and 300mg/Nm3 for NOx, when firing design fuel, on an average monthly rolling basis. A normal cubic meter of gas for this guarantee is defined as dry gas at OoC 101.3kPa and 6% O2 conditions. Please refer to Section 6.4 in Appendix E Air Quality Report. Previous to this the EPA SU had requested justification for non-compliance, which the proponent had provided, and had qualified independently by SKM and Katestone. In addition, the Appendix E air quality report used a higher emissions guarantee limit of 350 mg/Nm3 for NOx and 50 mg/Nm3 for dust (PM10) and it has been shown in this report that compliance with NEPM ground level concentration (GLC) guidelines has been achieved. Therefore due to the fact that the proponent has shown compliance with this inherently conservative approach no further amendments to the Air Quality Report are required.

POLLUTION DISPERSION ANALYSIS

Model Type 53, DEC

SKM endorsed the use of TAPM for modeling the dispersion of pollutants from the power station. The issue of TAPM’s ability to accurately predict ground level wind speeds was discussed with the DEC, and it was determined that as the emissions were from an elevated stack, use of CALPUFF (better able to resolve low wind speeds at ground level) was not warranted.

Inclusion of background data into TAPM

53, DEC

Background concentrations of particulates were included in the run-time simulation, by applying background data to the outer grid (inflow boundary) of TAPM. This data was applied in consultation with the CSIRO, who were also consulted with regard to the “dispersion” of background data to other grids. Background data for particulates have been applied as a post processing task. Background data for particulates have been applied as a post processing task.

Modeling of NOx and O3, specifically the inclusion of background concentrations of VOC’s and NOx given non-linear atmospheric chemical reactions

53

It is recognized that VOC’s, NOx and O3 react photochemically to influence the concentration of each pollutant on a diurnal basis. TAPM was therefore run using photochemistry mode (using the GRS not CTM), In consultation with CSIRO, a conservative “background level” of VOC’s was included, but specific biogenic/anthropogenic emissions were not included. Additionally, the


PAGE 75

reaction set is NOx limited, that is, an unlimited supply of VOC’s would be unable to react to form NO2 without the supply of NOx. Specific biogenic and anthropogenic emissions of VOC’s have been included on a grid basis as an input to TAPM. VOC’s emitted by the proposed power station were also included (as “in-plume” emissions). The accuracy of TAPM’s in photochemistry reaction set (GRS mode) was verified by modeling NO2 concentrations using:

− tracer mode (without chemistry),

− the ozone limiting method (OLM)

− chemistry mode (GRS) with biogenic and anthropogenic area/point sources,

A comparison of the various methods shows that chemistry mode results are similar to results using the OLM method, with both about 25% of the results using tracer mode. This is consistent with the expected concentration of NO2 from previous studies comparing measured stack emissions with measured ground level concentrations.

Background Concentration of NO2

53

NO2 was included post processing by simply adding the maximum concentration from Rolling Green (considered to provide a conservative estimate of NO2 given its rural location relative to Perth). It was recognized that a less conservative approach would be to include into TAPM, background concentrations on a grid basis, and to run TAPM in photochemistry mode. Biogenic and anthropogenic emissions of NOx has been included on a grid basis in TAPM using photochemistry mode (GRS). Anthropogenic emissions have been included on the inner most grid, while biogenic emissions have been included on the second most outer grid. These emissions have been applied based on the emissions listed in the NPI report for the Shire. Point source emissions from nearby major industrial sources (ie. Muja and Collie power stations) were also included (based on data acquired from the Bluewaters Power Station assessment). Background NO2 concentrations were compared with monitoring results for Bridgetown. Predicted background NO2 concentrations are less than assumed in the PER, but comparable to the background concentrations in Bridgetown.

Background concentration of Ozone

53

As noted above, Ozone is an important contributor to the photochemical reaction set. TAPM was run with a background concentration of 20ppb which increased during the daytime to a peak of about 50ppb. This was found to be consistent with scientific observations.


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Accuracy of TAPM at predicting meteorological conditions

DEC

3am data was not available for the chosen year (2001). It was assumed that the BOM data was measured at 10m, however as noted by the DEC, it was changed from ground level observations prior to October 2000, to 30m mast measurements (although long term BOM data is effectively at 10m). A comprehensive comparison of TAPM predicted meteorology with 2002 BOM measured meteorology was carried out by considering wind roses on a seasonal and annual basis, and diurnal basis. Wind class frequency distribution was also considered on a diurnal and annual basis. Correlation between predicted and measured wind direction and speed are relatively good, though TAPM does under predict the frequency of low wind speeds during nighttime. Notwithstanding this, there is a sufficient frequency of low wind speeds and direction to ensure an adequate level of conservatism of predicted ground level pollutant concentrations. Additionally, given the source of emissions is at 40m, and following discussions with the DEC in early 2007 regarding this issue, alternative prediction models such as Calpuff were not considered necessary

AIR EMISSIONS

AQ data for Manjimup may be available and once verified by the CSIRO should be used to demonstrate the appropriateness of the Bunbury data. Monitoring of PM2.5 has been underway in Manjimup since December 2006, and the use of this data is preferred.

52, 46

On commencement of the air quality assessments the DEC Manjimup office advised that no such data existed. We have since sought and received this data for validation of local conditions. This data has been compared statistically with data from Bunbury, with Bunbury data found to be higher or at least comparable with that in Manjimup. That is, use of the Manjimup data generally increases the safety margin with regards to the assessment criteria.

The biomass plant will contribute significantly to emissions of criteria pollutants in the Bunbury airshed. Exceedences are likely for PM10 & PM2.5 and possibly PAH’s and CO.

53

The air quality assessment has clearly demonstrated compliance with assessment criteria. No exceedances of these criteria are predicted. The outcome of the revised air quality assessment remains unchanged from the PER.

Inconsistencies in the "uncontrolled emissions" and "controlled emissions" values for PAH emissions are provided

41

The revised air quality assessment provides more detail in relation to “other” pollutants such as inorganic and organic compounds and trace elements. Additional reference material is provided to justify emission concentrations and the capture efficiency of the baghouse. The results are that emissions are significantly reduced in most cases.

PER does not address the net impact of oxides of nitrogen

41

Independent reviews of the PER air quality assessment recommended inclusion of biogenic and anthropogenic emissions of VOC’s and NOx to more accurately predict NO2 concentrations. These reviews also recommended comparing predicted concentrations of NO2 with and without inclusion of atmospheric chemistry to qualify the accuracy of predictions. These recommendations were


PAGE 77

followed, and predictions of NO2 were demonstrated to be reasonable using TAPM run in chemistry mode, and importantly, reduced concentrations of NO2 are predicted (ie. The PER provided a more conservative assessment). Refer to the revised air quality assessment at Appendix E(a).

Use of monitoring for Bunbury region not adequate for Manjimup area

GS1, 12, 16, 28, 6, 17, 53

Through the PER process, we were not advised of the availability of ambient air quality monitoring data for Manjimup. As a result, ambient air quality monitoring at Bridgetown was used and compared to comprehensive monitoring data for Bunbury (as provided by the DEC). Bunbury data was used as it was considered to provide a conservative estimate of ambient particulate concentrations given the increased population density and proximity to the coast (sea salt drift). A statistical comparison of Manjimup data with Bunbury data demonstrates that the use of Bunbury data provided a conservative assessment. Use of the Manjimup data in the revised air quality assessment has resulted in a less conservative assessment outcome, with a greater margin of safety. Refer to the revised air quality assessment at Appendix E(a).

The proponents have not adequately addressed the issue of background PM10 in supporting their claim. The DOH encourages the proponents to use the data to demonstrate the reduction in background PM10 that may be achieved with the power plant.

46

As noted herein, the use of ambient air quality monitoring data for Manjimup has generally resulted in reduced ground level concentrations of pollutants. The use of Bunbury monitoring data resulted in greater concentrations, however these also complied with the assessment criteria.

No consideration is given to pesticide residue that may be contained in the wastes and what levels could be released in the combustion process.

12, 16, 41, 53

The air quality modelling has been based on fuel samples provided from existing plantations. To ensure that the fuel is consistent with this standard, the proponents will negotiate appropriate plantation management agreements with fuel suppliers to ensure that the use of pesticides does not compromise fuel quality. The air quality management plan will require fuel to be randomly tested, to ensure fuel quality conforms to the specifications and standards modelled in the PER.

Analysis of eucalypt waste (CSIRO 2002) gave a value for chlorine in excess of 2,000 mg/kg, Such high levels will be conducive to production of significant amounts of chlorinated phenols and dioxins in a biomass furnace. (Note: Although the "ideal" temperature range for production of dioxins is 200 - 450 degrees C, dioxins will form as effluent gasses cool on their passage through the bag filter system

41

A fuel analysis has been carried out by CSIRO for both eucalyptus and pine plantation waste. Exucalyptus waste has a higher chlorine content (by a factor of about 10) than pine waste. The proponent has committed to controlling chlorine content through a fuel management plan. This plan will ensure the correct mix of fuel is maintained. Research has shown that the kinetic reactions responsible for the formation of dioxins never proceed to completion. This means that, in spite of over-abundance of chlorine (and other elements that constitute building blocks for dioxins), most of the available material is not converted to dioxins. Dioxins are formed from surface catalysed (mainly from the presence of copper oxide) reactions (on


PAGE 78

fly-ash) and gas phase formation, with the former believed to be the major contributor to dioxin formation. Of the surface catalysed reactions, the precursor route (preformed chlorophenols/benzene react at the surface) is the primary mechanism at high temperatures, and the de novo route (eventual elemental reaction sequence) is the primary mechanism at low temperatures. After formation on the surface of fly-ash, some dioxin diffuses to the gas phase, with the rest remaining on the fly-ash. The formation of dioxins is controlled in the following ways (regardless of chlorine content): • High temperatures and long residence time in

the boiler • Fast cooling of combustion products,

minimising the time flue gases spend in 200-

450°C (eg. preheating combustion air) • Use of baghouse filters (without catalytic

media) to capture fly-ash (containing dioxin deposits)

• Presence of other trace element oxides that inhibit catalysed surface reactions on flyash

The practices will be employed in the biomass proposed power station.

Blue gums are known to contain high levels of chlorine. There has been conjecture that chlorine has a negative effect on the bag house filters longevity and efficiency.

6, 30

Baghouse filters are constructed from PTFE coated material which does not react with chlorine. The supports for the filters are treated to prevent corrosion by chlorine. The effectiveness of the filters are continuously monitored to immediately identify failure.

Since publication of the PER, proponents claim that data tabulated in table 13.18 isn't estimated emissions from the plant. Also the information in Table 13.18 differs to that in the table on p39 of the Development Application. If alternative emissions data needs to be added it should be done in a supplement to the PER, and be subject to additional public comment.

47

The revised air quality assessment provides both controlled and uncontrolled emission estimates, and references substantiating these values. The PER inadvertently confused the reader as to what was controlled and what was uncontrolled emissions.

The levels of Sulphur Dioxide in the notional 7km radius of pollution emitted from the proposed plant will be 120x the level from diffuse sources in the Shire of Manjimup.

47

The annual total emissions of Sulphur Dioxide in the Shire of Manjimup is 20,000 kg/year, but this level does not include emissions from the burning of plantation waste, nor prescribed burning. The level of Sulphur Dioxide predicted from the power station is about 189,000 kg/year, or about 10 times as high as other sources in the Shire. Emissions from prescribed burning will be greater than this level.

The "controlled emissions" figures are nowhere to be found in the PER

31

The revised air quality assessment provides both controlled and uncontrolled emission estimates, and references substantiating these values.

Emission figures specific to the Manjimup proposal are not being provided

31 It is assumed this query refers to ambient air pollutant concentrations for Manjimup. As noted


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herein, ambient air pollutant monitoring data was acquired from the CSIRO and the commonwealth DEH, which substantiates the conservative approach taken with the use of Bunbury data in the PER. That is, average maximum (or 98th percentile) ground level concentrations (for total suspended particulates) of pollutants in Bunbury are greater than for Manjimup.

The power plant will emit approximately one third of the total amount of PAH emissions currently emitted in the Shire

41

The annual total emissions of PAH’s in the Shire of Manjimup is about 3,000 kg/year, but this level does not include emissions from the burning of plantation waste, nor prescribed burning. The level of PAH’s predicted from the power station is about about 74 kg/year, or about 40 times less than other sources in the Shire. Emissions from prescribed burning will be greater than this level.

Emissions of “other” pollutants 53

Gaseous and solid pollutants were predicted on a pro-rata basis using tracer mode results for gases (NO2, SO2) and particulates (PM10, PM2.5). It is very difficult to estimate background concentrations of other pollutants, other than through use of NPI emission estimates or other research papers.

AIR QUALITY IMPACTS

Will improve existing air quality of the area as uncontrolled burning will be reduced. Burning of mill and plantation waste in the winter months has a huge impact on air quality, visual impact and odour which is noticed by residents and tourists alike. Controlled emissions, as opposed to the significant amount of waste burnt in the open, even though over a wider area, is better for air quality. The proposed plant offers a cleaner solution to this issue.

GS2, GS4, 1, 2, 9, 18, 20, 39, 55, 56, 49, 37, 36, 34, 32

Currently 380,000 tonnes of plantation waste is burnt in the open across an area of about 10,000 hectares. Emissions from this practice have been calculated by Connell Wager to be about 20 times greater than those from the biomass power station. This has also been verified by SKM in their submission to the Manjimup Council. Emissions may be even greater if open burning does not occur in the fire danger season (ie. The same amount of plantation waste currently burnt in the open burning is compressed into only 6 months of the year). The proposed biomass power station will remove this source of uncontrolled emissions to the environment, thereby improving air quality throughout the region.

Has there been sufficient evaluation of the health risk. The review of the AQ Assessment been undertaken by the Dept of health should be available to the public.

54

The proponent commissioned Toxikos to carry out an independent Health Risk Assessment (HRA). The HRA considered health risk associated with a range of pollutants including the criteria pollutants, as well as “toxic” pollutants such as Dioxins, PAH’s etc. The HRA concludes that, based on the 98th percentile cumulative concentrations of power station emissions and background air quality, it would be very unlikely health effects would occur.

Potential for acid rain 16

Acid rain is formed from the reaction of high level emissions of SO2 and NOx with water vapour. Given predicted concentrations of SO2 and NOx comply with environmental criteria, the potential for acid is eliminated by limited emissions of SO2 (about 12% of the 1 hour limit) and NO2 (about 28% of the 1 hour limit).

Open burning will not reduce significantly 53 Plantation waste is currently burnt in the open. In


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anyway because DEC will have to do still perform regular burns.

addition, the DEC also carries out prescribed burning, which results in even greater concentrations of air pollutants. The proposed biomass power station will remove one source of uncontrolled emissions to the environment, resulting in improved air quality for the region. The DEC carries out prescribed burning to properly manage bushfire risks that could otherwise devastate the region. A prescribed burning management plan could be established to also reduce emissions.

Effects of concentration of burning in a small area

11, 12, 27,

Plantation waste will be burnt using a fluidised bed combustion process which will ensure complete combustion of the fuel. Any pollutants remaining in the flue gas will be extracted as the gas is blown through a filter. The flue gas will then be exhausted at 40m above ground level at a velocity adequate enough to propel the “plume” (invisible) of hot air to an even greater height. The plume will rise due to buoyancy (given its temperature is greater than that of surrounding air), and as it rises, it will be dispersed by the prevailing wind. The science behind this dispersion process has been validated for thousands of industrial (and non-industrial) sites throughout the world. This is considerably different to open burning of plantation waste at ground level, with inefficient combustion resulting in a high level of particulates that are drift at ground level across the region, including onto nearby vineyards and orchards, at ground level concentrations estimated to be 20 times greater than those predicted from the biomass power station.

Comparison with other plants

53

The PER (Section 3.3) includes details of local and international examples of power stations fuelled with biomass. A graphical comparison of biomass fuelled power stations in Europe and North America, are shown together with major wine regions (which are considered by some to be most sensitive to pollutant emissions) in the Smart Viticulture report (refer Appendix D).

Boiler Startup/Shutdown

53

Boiler startup with distillate firing has not been addressed in the PER. Emissions of NOX, SO2 and particulates may be higher when firing the boiler with distillate fuel. The PER considered emissions due to baghouse failure but not startup/shutdown emissions due to the short duration of these emissions, and the difficult in estimating emissions and conditions during these events. Startup using distillate will affect only short term emissions of gaseous compounds (NO2, SO2, CO), and startup will occur for less than 30 minutes. The operational management plan will ensure shutdown procedures have minimal impact on emissions (ie. Continue forced and induced draft fans until final fuel injection is fully combusted). The type of distillate used during


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startup has not yet been determined, and additional modeling will be carried out to ensure emissions are adequately controlled.

Risks to vulnerable population – young pregnant and elderly (need to conduct health surveys on children)

2, 6, 11, 12, 13, 17, 19, 22, 24, 26, 28, 30, 31, 35, 41, 42, 47, 48, 50, 68 and Group Submission 1

The proponent commissioned Toxikos to carry out an independent Health Risk Assessment (HRA). The HRA considered health risk associated with a range of pollutants including the criteria pollutants, as well as “toxic” pollutants such as Dioxins, PAH’s etc. During the risk assessment analysis, the most vulnerable people (e.g. children, the sick and elderly) are carefully considered. Conservative safety margins are built into a risk assessment analysis to ensure protection of the public. Therefore people will not necessarily become ill even if they are exposed to materials at higher levels than those estimated by the risk assessment. Commensurate with common international practice, a safe exposure level for the substance is taken to be the ambient air guideline established by a competent authority. Air guideline values (i.e. standards) are established with protection of the most vulnerable people in mind and usually contain wide margins of safety (NHMRC 2006). The HRA concludes that, based on the 98th percentile cumulative concentrations of power station emissions and background air quality, it would be very unlikely health effects would occur. Based on the above analysis it was not considered necessary to conduct health surveys.

Odour impacts were not considered


The most important combustion products for odour impacts include NO, NO2 and SO2. Wood is inherently low in sulphur content as demonstrated by both NPI and US EPA AP-42 estimates and generally referenced from other Biomass Power Stations. Odour thresholds for NO and NO2 are typically 865µg/m3 and 216µg/m3 which is equivalent to the hourly maximum NEPM limit. Compliance with the NEPM therefore ensures odour will not be an issue. In addition, within Section 13 "Modelling Results and Impact Assessment "section of the air quality report a comparison has been made between the NEPM guideline level and it is shown that there is compliance with the NEPM air quality GLC limits. Section 13.1.2 (Results for NO2 analysis) has detailed several different methodologies through which there is proven compliance with the NEPM limit, both absolute worst case scenarios and more realistic assessment scenarios. Section 10.2 discusses Atmospheric Chemistry and the various methods that have been used to assess the worst case NO2 GLC impact. This section also discusses the atmospheric chemical transformation of NO to NO2 in the presence of VOCs and O3 (the reaction cycle).


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EMISSIONS CONTROL

Technology is out of date 11

The choice of a fluidised bed combustion boiler and baghouse are technologies that are considered best practice based on the Integrated Pollution Prevention and Control (IPPC), Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006).

Does the PER address the emissions produced using a dry bag filter

41

The baghouse consists of a series of fabric filters which capture particulate emissions. No water spray or steam is applied to the flue gas. The revised air quality assessment lists the efficiency of the baghouse at removing various pollutants.

Emission controls lower than for Bridgetown proposal and best practices (West Australian - 16/01/08)

53

The choice of a fluidised bed combustion boiler and baghouse are technologies that are considered best practice based on the Integrated Pollution Prevention and Control, Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006).

Bag House Filtration Issues: What is the backup if bag system fails? Bag house failure not included in worst case scenario modelling. Bag technology inadequate. Community needs to assured that Bag filtration Exhaust Cleaning is a well demonstrated and effective technology.

10, 53, 54

Sec 3.2.6 shows the guaranteed emission rates associated with the bag technology. Each baghouse includes an integral poppet damper so that each individual baghouse can be isolated. The two parallel bag filter streams, each one capable of handling 100% load, allows for on-line cleaning and maintenance of the bag filter house without effecting the power plant output. The system is designed so that if one baghouse is isolated for online replacement of bags (for up to 24-36 hrs) the emission limits can still be achieved without turndown of the load on the boiler. (Sec 13.6.2). Emissions control technology will be constantly monitored by measuring the pressure across each bag filter. Should the pressure noticeably increase/decrease from a prescribed range, that section of the baghouse will be immediately shutdown and flue gas immediately bypassed to the standby section. If both sections fail, the plant will be immediately shutdown. Baghouse failure modelling has been undertaken and results are shown in section 13.12.3 of the PER.

Will limestone or dolomite be used within the atmospheric fluidised bed to capture sulphur released by combustion - Sec 13.6.1

52

The sulphur level in the fuel is very low and does not justify the use of limestone or dolomite. In operation if the levels were to increase the use of limestone or dolomite will be considered. These can be added either in the fluidised bed or even be injected in flue gas steams. The IPPC Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006) notes that “… wood biomass contains practically no sulphur. Wood-based biomass can, therefore, be combusted in FBC [sic. Fluidised Bed Combustor] without desulphurisation. The SO2


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emission level depends thus only on the sulphur content in the fuel and is typically below 50 mg/Nm3 (O2 = 6 %)”. An emissions guarantee has been obtained from the proponent.

Why aren't wet scrubbers being used for Manjimup. A combination of both would result in better emissions.

16, 17, 19, 41, 50, 53, 30

Wet scrubbers are used to control SO2 emissions. As noted above, the IPPC Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006) notes that “… wood biomass contains practically no sulphur. Wood-based biomass can, therefore, be combusted in FBC [sic. Fluidised Bed Combustor] without desulphurisation. The Sulphur content of the fuel is minimal, as determined by an analysis of fuel samples. The proponent has committed to an emissions guarantee based on the Sulphur content of the fuel. Wet scrubbers (and dry desulphurisation) are not required. Contrary to some public opinion, wet scrubbing was not proposed for the previous Bridgetown site. However, cooling towers (towers with fans that draw air through a water spray) were proposed for the Bridgetown site to provide chilled water to condense steam from the turbine. The Manjimup uses Air Cooled Condensers, which are larger and do not rely on the injection of water to provide chilled water to condense steam.

Have investigations been undertaking regarding using the REMEDIA D/F catalytic filter system for dioxin control - Section 3.26

52 DEC

REMEDIA filters are essentially bag filters with a catalytic inhibitor bonded to the filter media to inhibit the passage of Dioxins/Furans. REMEDIA filters are generally recommended where high level of dioxins is present, especially in incinerators using municipal wastes. In this case dioxins levels are much below the recommended levels and use of filters such as REMEDIA is not considered necessary. The IPPC notes “In some biomass fired plants, especially wood-fired combustion plants, the emissions of dioxins and furans have been measured and an emission level of below 0.1 ng/Nm3 is generally regarded as achievable.” With best available technology (which at present does not include REMEDIA filters).

AIR QUALITY MANAGEMENT

PER does not address management plan for the cleaning of the bag filters

41, 17 Addressed in Sections 3.2.6 and 13.12.3 of the PER. Refer also to section 3.3 of the revised air quality assessment.

Several large sawmills operated in the area in the past resulting in smoke generation. Exhaust smoke can be managed.

1, 36, 20

The proposed biomass power station will not emit a visible plume of smoke as all pollutants are extracted, and no wet scrubbing processes take place in the flue gas stream.

Air Quality management plan should include details of contingency plans and include trigger levels for significant pollutants, which exceeded would require implementation of these plans.

52

The air quality management plan includes regulatory limits for “criteria” pollutants, as well as pollutants classified as air toxics. These criteria have been established by the Commonwealth based on minimising risks of human health impacts. These criteria relate to ambient air concentrations. In addition, in-stack pollutant


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concentrations will be monitored in real-time, with “trigger” levels determined from either emission guarantees and/or the results of air dispersion modelling, used to implement actions plans if an exceedance is identified. These action plans include shut down of the plant if necessary.

AQ management plan should include: - The steps that will be taken in the event of emission control technology failure and the anticipated level of inefficiency that may trigger a response. - A commitment to provide verification of modelling results by continued AQ monitoring. - Routine fuel sampling to include ash sampling and chemical analysis for heavy metals. Including a management strategy for handling potentially contaminated ash. - Real time stack monitoring to include detailed analysis of pollutants to ensure that levels of pollutants comply with the limits guaranteed by the proponent.

46

The key elements of the air quality management plan include: − Baseline monitoring of ambient air pollutant

concentrations prior to operation, together with meteorological monitoring at a fixed location. Baseline monitoring will be carried out at a minimum of 3 sensitive receptors around the plant. Monitoring will be carried out for a minimum period of 12 months


− Monitoring will include but not be limited to criteria pollutants (NO2, SO2, CO, O3, Pb, PM10, PM2.5 etc) and air toxic pollutants (PAH, PCDD/F, Trace Elements)

− Emissions control technology will be constantly monitored by measuring the pressure across each bag filter. Should the pressure noticeably increase/decrease from a prescribed range that section of the baghouse will be immediately shutdown and flue gas immediately bypassed to the standby section. If both sections fail, the plant will be immediately shutdown.

− Routine fuel sampling will ensure the correct mix of fuel is maintained, consistent with that specified and modelled in the PER.

− Air quality monitoring results will be used to rerun the air quality model to verify its accuracy.

− Ash will be routinely sampled to determine its suitability for a specific landfill classification.

The proponent is committed to ensuring emissions comply with regulated emissions criteria through an ongoing routine air quality management plan.

Would better dispersion occur with a higher stack.

17

The stack height is one method used to improve dispersion of pollutants. Other methods include exit velocity and temperature. The stack height relative to the elevation of surrounding terrain is an important consideration. The power station is located about 270m AHD, with the highest point within a 3km radius being about 280m AHD. The height of the stack (40m) is therefore well above the highest point within 3km. Stack height effects local concentrations (within about 2km), with minimal effect on distant (about 10km) concentrations. Given the maximum pollutant concentrations from the power station are an order of magnitude below existing ambient concentrations, no further increase in stack height is warranted.


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Monitoring of Dioxins


The proposed monitoring program includes: − Baseline monitoring of ambient air pollutant

concentrations prior to operation, together with meteorological monitoring at a fixed location. Baseline monitoring will be carried out at a minimum of 5 sensitive receptors around the plant. Monitoring will be carried out for a minimum period of 12 months


− Periodical monitoring will include but not be limited to criteria pollutants (NO2, SO2, CO, O3, Pb, PM10, PM2.5 etc) and air toxic pollutants (PAH, PCDD/F, Trace Elements)

The European Union established legally binding Directives with a high level of environmental protection. European standard, EN 1948, "Stationary Source Emissions - Determination of the mass concentration of PCDDs/PCDFs", was developed as the reference method for monitoring the limit value of 0.1 ng I-TEQ/Nm3. This is similar to USEPA (1995) Method 23 “Determination of Polychlorinated Dibenzo-p-Dioxins (PCDDs), Polychlorinated Dibenzofurans (PCDFs) from Stationary Sources”. The USEPA method is approved by the NSW DEC for monitoring of dioxins or furans. It is proposed that monitoring will be carried out using either of these methods.

Use of best practice technology related to dioxins and greenhouse gas emissions


The choice of a fluidised bed combustion boiler and baghouse are technologies that are considered best practice based on the Integrated Pollution Prevention and Control (IPPC), Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006). The Stockholm Convention for Persistent Organic Pollutants (POP’s) notes that for biomass-fired plants, particularly wood-fired installations, emission levels of persistent organic pollutants associated with best available techniques are generally below 0.1 ng I-TEQ/Nm3. The concentration of POP’s from the proposed biomass power station (0.038 ng I-TEQ/dscm) complies with the recommended level. This claim is further verified by the IPPC; “In some biomass fired plants, especially wood-fired combustion plants, the emissions of dioxins and furans have been measured and an emission level of below 0.1 ng/Nm3 is generally regarded as achievable.” The levels of POP being emitted from the plant are substantially below recommended levels. The proposed technology to be adopted is considered to be best practice for this type of facility.

Relevance of NSW EPA Air Quality Management to WA

2, 6, 11, 12, 13, 17, 19, 22,

The EPA is preparing to develop a draft Environmental Protection Policy (EPP) for Ambient Air Quality in accordance with prior commitments


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24, 26, 28, 30, 31, 35, 41, 42, 47, 48, 50, 68 and Group Submission 1

to implement the Ambient Air Quality National Environment Protection Measure (NEPM). It otherwise relies on Federal legislation to control emissions. The Department of Environment and Conservation (NSW) developed “Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales”, which are equivalent to those developed for Victoria (and South Australia), and are based on criteria developed by the USEPA. They are relevant to the assessment of air toxics in WA as WA has no other methods for assessing air toxics, and the methods described are slowly becoming adopted by all other states.


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4.6 Noise Quality

A low number of submissions raised concerns or offered comments on the impact of noise associated with the proposed plant. The main concern was as to why the noise modelling undertaken did not include the noise associated with the delivery trucks. Section 14.10 of the PER shows the noise modelling undertaken for a worst case scenario estimates a noise level of L1028 dBA at the nearest existing receiver during the night time. When combined with the materials handling noise sources this gives a level of 33 dBA which complies with the assessment criteria of L1035 dBA for the night period. Table 4-7 Noise Quality Issues & Statements


Response

Noise pollution concerns especially during the night

12, 53

Noise modelling has shown that noise levels at the nearest receiver will conform to the assessment criteria of L10 35dBA for the night period – Refer to the PER Section 14.10

Noise of delivery trucks (not considered in modelling)

11, 12, 17

The PER has addressed potential for increase in noise levels associated with road traffic volumes. Refer Section 14.2.3, and 14.5.3. Table 14.12 of the PER demonstrated that the highest increase in noise is 3.5dB on Eastbourne Road on a weekday when comparing existing traffic volumes with predicted volume increase and subsequent noise level increase. This location has a noise rating of N0 where the acceptable increase in noise level (Leq) is “4dB or up to N0 level, whichever is greater” in accordance with EIA No.14.

Developer sets and monitors noise limits for contractors

6, 41

The PER Noise Management Plan includes provision for noise measurements (by the developer) of equipment to be carried out to ensure vendors/contractors meet their noise guarantee commitments, at commissioning stage. Following commissioning of the power plant, an environmental noise survey shall be conducted at the noise sensitive boundaries with the plant operating as close as possible to its design capacity (see PER Section 14.10.3) to ensure compliance with EPA Guidelines.

Relevant noise criteria are to be met 8,

Section 14 of the PER has demonstrated through modelling of predicted noise levels that the relevant noise and vibration criteria will be met, and that the plant will operate in accordance with the relevant noise and vibration regulations detailed in Section 14.2.

Location of fuel storage differs in Figures 8-9, 9-2, 14-3 & 14-14 to Figure 3-1 (dated 15.01.08). these may have implications on noise modelling. A revised noise assessment should be undertaken for new fuel storage location. Comments from AQ Man Branch of DEC regarding meteorological data should be taken into account.

52

The fuel storage location has been relocated since the PER. The fuel storage acts to provide shielding of noise locally and provides limited mitigation of noise to sensitive receptors. The model output has been updated with the revised storage location. Contours have been generated in close proximity to the plant and at such a distance as to include sensitive receptors located around the plant. These revised contour maps are provided in Appendix F.


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4.7 Surface and Groundwater

Of the submissions received, the main issue raised with relation to water was the possible adverse impacts (primarily health) that emissions will have on rain water used for drinking water supply. Concerns were also raised as to the impact that emissions will have on local surface water bodies and the Manjimup town water supply. While the assessments undertaken by CSIRO Land and Water and Toxikos (Health Risk Assessment) have concluded that emissions from the proposed power station present unlikely or negligible health risks (see Appendix C and Appendix H) the proponent will undertake an investigation and management process including representative sampling of drinking water supplies in the locality based on Australian Drinking Water Guidelines 2004 prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly. A meeting was held with the Department of Water (DoW) on March 13th, 2008 to discuss the issues highlighted in its submission to the EPA. The primary concerns raised by the DoW were that insufficient detail was provided as to how stormwater would be managed within the site and the overall impact the plant would have on the quality of local surface water and groundwater bodies. A site water balance model was developed to demonstrate that water can be managed on site, without impact on the public drinking water source areas. Additional investigation into stormwater modelling and proposed management options is provided in Appendix G(a). The proposed plant will incorporate a zero process water discharge policy. Process water will not be discharged to the local environment, but instead be used in the ash wetting process. Waste products such as ash will be subject to a management regime including sampling and disposal methods. High Risk stormwater has the potential to be generated within the areas surrounding hydrocarbon storage areas, workshop facilities, and any other locations where hydrocarbons and chemical substances are to be used or stored. High risk areas will be bunded, and where appropriate hydrocarbon and chemical storage areas will be roofed, or else these substances stored in-doors. Any stormwater collected in these areas will be either removed off-site for treatment or passed through oil-water separators and the waste collected and taken off-site by licensed contractors. For the biomass storage area, stormwater runoff and leachate will be directed into a retention pond that is hydrologically separate from the remainder of the stormwater system. It is then proposed to reuse all of the water collected in this pond for dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant. Stormwater from the biomass storage area will not be discharged off-site. For the remaining plant area of the site, two options are currently being investigated to manage the associated stormwater. One option involves capturing the stormwater in a sediment pond followed by secondary treatment (if required) in bioremediation devices to reduce nutrients, dissolved metals and other contaminants of concern via extended detention, vegetation, and/or soil filter medium. The treated stormwater would then be discharged to the local drainage system. The second option involves capturing this stormwater in a holding pond and utilising it in dust suppression, ash wetting and as feed water to the RO/EDI treatment plant for process water. Where the option of discharging treated stormwater is pursued, stormwater will be treated to the background water quality levels of the receiving water bodies, thereby eliminating the potential for the pollution of these receiving environments. Water quality exiting a properly designed and maintained sediment pond from the Plant area is expected to be able to comply with reasonable suspended solids and turbidity limits as generally set during construction. If further treatment is required, further polishing to remove finer sediment, nutrients and metals will be undertaken in bio-remediation devices such as swales or bio-retention basins. Discharge will be to the local drainage catchment which has been identified as the East Brook catchment. It should be noted that the East Brook catchment discharges downstream of the Pemberton town water supply weir.


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Further details regarding stormwater management for the plant are provided in Appendix G. A sample of water from the existing WAPRES water supply dam was tested (19 February 2008) to determine pre-development water quality levels within the dam. Each of the parameters tested are illustrated below and compared with water quality levels in the Lefroy Brook which were taken as part of the DOW water monitoring programme.

WAPRES supply dam Water Quality

Parameter Unit Lefroy Brook (site 6071106)

Lefroy Brook Tributaries (north west)

(sites 6071031, 6071095)

WAPRES dam sample (1 occasion)

Colour TCU or Hu 47.7 11.4

BOD5 mg/L 4.3 <5

Total N mg/L 0.543 0.68

Total P mg/L 0.194 0.050

Salinity mg/L 240 TDS mg/L 394 250

Conductivity mS/cm 0.41 Turbidity NTU 5.4 7.6

pH (none) 7.3 6.9 7.1 As a result of the additional investigation undertaken (presented in Appendix G(a)) the Department for Water has commented that the proponent has the technical capability to manage water resource quality issues at this site, however should the EPA recommend this project as acceptable, stringent conditions should be set and commitments obtained from the proponent that adequate water quality protection measures will be installed to protect present water values and a future drinking water source on the Warren River(if the power station is to have an operational life beyond 25 years). Correspondence from the Department is provided at Appendix G(b). It is considered that through the proposed management plans, and with detailed site design, the requirements of the Department of Water can be adequately met. Responses to specific issues raised in submissions are detailed below. Table 4-8 Surface and Groundwater Issues & Statements


Response

WATER USE / PROCESS WATER BALANCE

Water impacts will be minimal as the supply is from the existing dam, the process creates no discharge, and no chemicals are used in the process.

GS3, 9

Noted. A water supply dam exists on site, and a detailed site water balance has been developed to ensure minimal impacts on the surrounding environment.

If plant proposes to use 24ML p.a. and there is no process water discharge, where does the water go.

53

There is some water loss through the process from evaporation and boiler blow-down. The balance of process water discharge will be used in the ash wetting process as detailed in Section 4. This results in a zero process water discharge from the site.

Agricultural land has been converted to plantations in most of the river catchments. Vast areas of uniform young eucalypts suck the catchments dry. Consequently, water becomes scarce

50,

The proponent is relying upon fuel provided by existing committed plantations. Hence this issue seems beyond the scope of the PER. The proponent is not aware of evidence to suggest that the plantations managed by the contracted


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and more expensive for the farmer. suppliers have reduced water runoff to catchments. The proponent has, however, designed the plant to have minimal impacts on the local water resources. Water use in the process itself is being minimised through the re-use of process water for ash wetting purposes and the use of an air cooling system. Stormwater generated in the biomass fuel storage area (and potentially the plant area) will be utilised for moisture control, dust suppression and as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant. This further minimises the use/extraction of water from nearby water bodies.

Concerned that the project proposes to both increase water use and increase water removal from the surrounding environment. Every effort should be made to minimise water use and maximise water re-use or recycling.

66

Every effort is being used to re-use and recycle water. Used process water will be used in the ash wetting process. Stormwater generated in the biomass fuel storage area (and potentially the plant area) will be utilised for moisture control, dust suppression and as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant. This demonstrates that water re-use is being maximised.

What are the implications for water resources if the Biomass Power Plant was required to use "wet scrubbing" processes to control emissions rather that the presently proposed "dry bag" processes? Are wet scrubbers not being proposed due to lack of water supply on-site?

16, 17, 31, 44

Wet scrubbers are a highly water intensive process, requiring approximately 125 ML/yr additional water. In addition, such a process also requires additional area (more space) for recycling of water and ash (sludge) handling, and consumes additional power for pumping and processing. It has therefore been considered inappropriate to use wet scrubbers on this site. Bag filtration is considered best practice.

WATER QUALITY

Are the primary point source pollutants of significance for Water Quality in the dams?

44

Primary point source pollutants will be treated to the required standards and will therefore not be of significance for Water Quality in the dams. In accordance with EPA requirements through the Water Management Plan, a program of monitoring and water management (to be developed in consultation with the DEC and DoW) will ensure water quality is managed appropriately.

Impact of emissions (possible secondary pollutants) on water quality in groundwater, dams and rainwater tanks, as well as cumulative impact. Testing of dams and tanks. Local farmers (if willing) should have their WQ measured so baseline data is available. Manjimup town water supply is within the emission zone and needs detailed

GS1, 6, 11, 12, 14, 17, 19, 23, 30, 31, 42, 44, 46, 47, 48, 50, 53, 64, 65

The proponent will undertake an investigation and management process including representative sampling of drinking water supplies in the locality based on Australian Drinking Water Guidelines 2004 prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly.


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consideration with respect to potential impacts.

Impacts of emissions (inc ash disposal) on surrounding surface water bodies

GS1, 31, 48, 50

Water and ash sampling will be undertaken to determine whether ash is suitable to be disposed of on land for agricultural purposes. Ash will only be used for agricultural purposes after it has undergone sampling to confirm it is suitable for such purposes. A sampling regime will be developed in consultation with the DEC. Where not suitable it will be disposed of in an appropriately classed landfill as per the requirements of the Landfill Waste Classification and Waste Definitions 1996 (As amended) and Department of Environmental Protection 2002, Guidelines for Acceptance of Solid Waste to Landfill. The proponent will undertake an investigation and management process including representative sampling of surface dams in the locality prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly.

SITE WATER MANAGEMENT

Seepage of contaminants into the water table. Entire site should be concrete or bituminized to eliminate seepage

30,

Seepage of contaminants into the water table is not expected to occur. Process water will not be discharged off site. High risk areas will be bunded, and where appropriate hydrocarbon and chemical storage areas will be roofed, or else these substances stored in-doors

Lack of background surface and groundwater data and need for more up to date data

6, 17, 53

All available background data for the area has been provided. Baseline data on water quality in surrounding dams will be collected prior to commissioning of the plant. In accordance with EPA requirements through the Water Management Plan, a program of onsite monitoring and water management (to be developed in consultation with the DEC and DoW) will ensure up-to-date data is collected. Existing water quality in the WAPRES dam has been provided above in addition to water quality data from two monitoring sites on the Lefroy Brook.

Backloading may contaminate trucks with plantation residue and downgrade the quality chips currently provided to overseas buyers. An additional washdown facility and additional water contamination facilities with supply may be required.

19, 50

The current practice between carting different types of timber or woodchip is for the driver to sweep the truck out. The trucks have ‘walk-in’ floors which make this possible. Trucks are only washed out if soil/rock/lime etc (a non-timber product) is carted prior to a load of woodchips being loaded. Therefore additional water facilities will not be


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required for the washdown of trucks for backloading of biomass fuel.

Water not to be discharged to local water supplies

GS2, 18, 9, 55, 58,

No process water, high risk stormwater or stormwater generated within the biomass fuel storage area will be discharged off-site. There is the potential for stormwater from the remaining plant area to be discharged off site, but only after it has been treated to the ambient water quality levels of the receiving water body. Further details are provided in Appendix G.

The PER does not adequately address the potential impact of increased water storage and use on downstream surface and/or groundwater dependent ecosystems. Prior to approval for increased water use, the proponent needs to investigate and report on potential impacts from decreased environmental flow on downstream water dependent ecosystems and identify how these impacts could be managed.

51

The proposal to expand the dam storage capacity has been flagged as a potential requirement post-operation, if required. In view of the capacity of the existing dam, its anticipated annual yield and the volume of water required by the plant and Mill operations this is considered a low probability. Should additional storage be required, the proponent would undertake the investigation required to report on potential impacts from decreased environmental flow on downstream water dependent ecosystems and identify how these impacts could be managed, prior to applying for the necessary approvals. It should also be noted that stormwater generated in the biomass fuel storage area (and potentially the plant area) will be utilised as feed water to the RO/EDI treatment plant for polishing prior to use in the power plant, thereby reducing the need for water extraction from the existing WAPRES dam.

The proponent should provide a water balance for the proposal that indicates the likely significance of proposed reductions in environmental flows, particularly for the Lefroy brook catchment

51

A Process Water and Demineralised Water Balance Diagram have been provided in Figures 4.1 & 4.2 of the PER respectively. A conceptual stormwater flow diagram is provided in Appendix G.

The PER does not provide sufficient design details or water balance modelling to demonstrate that contaminated run-off can be prevented from leaving the site under all circumstances, particularly over the winter months of above average rainfall

63

No process water, high risk stormwater or stormwater generated within the biomass fuel storage area will be discharged off-site. Dams are sized based on the flows and volumes associated with a 1 in 10yr, 24hr storm event. There is the potential for stormwater from the remaining plant area to be discharged off site, but only after it has been treated to the ambient water quality levels of the receiving water body. Further details are provided in Appendix G including water balance diagrams.

The document does not describe what the contaminants are within the demineralised water, whether they are detrimental to the environment and how and why they will not enter the environment

51

The quality of the water supply from the dam is detailed above. The water treatment plant proposed for the Power station is for generating demineralised water to be used as boiler water make-up. The process envisaged is a combination of Reverse Osmosis (RO) and Electro De-ionisation (EDI). Neither of these processes requires use of


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chemicals. Additionally, the treatment plant will be housed in a building. Any waste from the process will be managed as per the approved waste management plan. The zero process water discharge policy is proposed to be applied.

Although the site falls outside the area proclaimed under the Country Areas Water Supply Act 1947 as the Lefroy brook Weir catchment, it will fall within the physical catchment area of Lefroy Brook if site drainage is directed to the west. It is unclear from the PER into which sub-catchment the finished site surface stormwater will drain.

63

Where treated stormwater is to be discharged off site, it will be discharged to the natural drainage system to the south-west of the site which belongs to the East Brook catchment. The East Brook catchment enters the Lefroy Brook below the Pemberton town water supply weir.

The proposed site is also located within the Warren River Water Reserve which is proclaimed under the Country Areas Water Supply Act 1947. The Department of Water is opposed to the development of new activities in the catchment that have significant potential to degrade the quality of water resources.

63

The proposed site lies in the East Brook catchment which enters the Lefroy Brook below the Pemberton town water supply weir. No process water or stormwater will be discharged to the Warren River Water Reserve, and therefore the proposal will not have potential to degrade the quality of water resource within the Warren River catchment.

Are there water resource management implications of disposal of ash from the Biomass Power Plant if it were to be disposed on land in 'local' water catchments?

44

Ash sampling will be undertaken to determine whether ash is suitable to be disposed of on land for agricultural purposes. If it can be safely applied to agricultural land it will act as a soil enrichment agent. If not, and if there is no alternative use for the ash product, it will be safely disposed of to an appropriately licensed landfill site.

Water related technical concerns regarding the power station proposal. Potential contamination form: Colour, BOD, Petroleum Hydrocarbons, Metals, Nutrients, Toxic Organics, Pathogens, Pesticides, pH, Salts, Surfacants, Turbidity and Suspended Solids.

63 Details regarding potential contamination and the management measures proposed are provided in Appendix G.

Inadequate description of catchments and brooks.

6, 12, 17, 19, 30, 31, 41, 42, 47, 48, 50, 68 and Group Submission 1

The site lies in close proximity to the boundary of 3 catchments as illustrated in Figure 11.1 of the PER. The Diamond Tree Gully lies to the east of the site and discharges to the Warren River Reserve catchment. The Lefroy Brook lies to the north-west of the site and discharges to the Lefroy Brook Weir catchment. Any stormwater from the site will not drain to these water bodies due to topographical constraints. The East Brook lies to the south of the site, and this is the waterbody which drains the site. The East Brook ultimately discharges to the Lefroy Brook Weir catchment, however it enters the Lefroy Brook downstream of the Pemberton town water supply weir. Based on this, if discharge of low risk treated stormwater is proposed, it will not impact on the Pemberton town water supply.


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The site falls outside the area proclaimed under the Country Areas Water Supply Act 1947 as the Lefroy Brook Weir catchment area. The Lefroy Brook Weir catchment in which the site ultimately lies comprises of a total area of 25,192ha. The long-term average annual flow for the Lefroy Brook Weir catchment is estimated to be 49 400 ML and the long-term average yield is 822 ML/year. Land use within the catchment is classified and separated into the following land use types:

• Rural land – 10,310ha (41%) • State Forest – 13,870ha (55%) • Other Crown Land – 947ha (3.75%) • Special Rural – 65ha (0.25%)

The dominant land use in the catchment is State forest. Timber production by the Forest Products Commission (FPC) is the dominant commercial activity undertaken in the State forest. There is a high proportion of rural land use in the catchment which is classified Priority Agriculture under the Shire of Manjimup Local Planning Strategy. Existing land use activities include cereal cropping, grazing, annual and perennial horticulture including viticulture, orchards and silviculture, aquaculture, nurseries, small scale tourist activities and accommodation, and a small number of industrial businesses (bulk transport and timber treatment). Other Crown Land classifications in the catchment include road and rail reserves, timber reserves and Public Open Space. A small area of Special Rural is located at the top of the catchment (Lefroy Brook Catchment Area Drinking Water Source Protection Assessment, Water Corporation 2004).

Stormwater run-off into catchments 6, 12, 17, 19, 30, 31, 41, 42, 47, 48, 50, 68 and Group Submission 1

From the information provided above it has been shown that the site is located within the East Brook sub-catchment. This sub-catchment eventually discharges to the Lefroy Brook, however this occurs downstream of the Pemberton town water supply weir, thereby not impacting on the water quality of the Pemberton town water supply. There is the potential for stormwater from the low risk areas of the plant to be discharged off site, but only after it has been treated to the ambient water quality levels of the receiving water body. Further details are provided in Appendix G including water balance diagrams.


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4.8 Flora and Fauna

In submissions regarding flora and fauna, the adequacy of the flora and fauna study was questioned. The potential for impact on the area surrounding the site from air emissions with particular regard to sensitive aquatic fauna was raised as a concern. Statements were also received outlining that the proposed site is located in an existing industrial area, and impacts on flora and fauna would therefore be minimal. The scope of the flora and fauna study took into account the nature of the site, having been previously cleared and used for timber milling and transportation purposes. The data provided by the Department of Environment and Conservation is robust at the concept investigation stage in determining the potential impact on species recorded as being threatened or vulnerable in the wider locality. CSIRO Land and Water undertook a review the potential effects of pollutants predicted to be emitted from the proposed biomass power station on plants and agricultural crops in the surrounding area (see Appendix C). This review concluded:

• hazards from particulates are likely to be low, and restricted to areas very close to the plant. • The predicted direct toxicity hazards from SO2 emissions to plants and crops were

predicted to be negligible. • The predicted direct toxicity hazard from NO2 emissions to plants and crops are predicted

to be acceptable. • The predicted direct toxicity hazards from emissions of dioxins/furans to agricultural crops

were predicted to be acceptable. • monitoring of emissions will be undertaken once the plant is operating to ensure predicted

emissions are in line with actual emissions, and that actual emissions are within regulatory limits.

The Department of Health provided key recommendations for the management of weeds and dieback, which have been incorporated into the revised management plan. Table 4-9 Flora and Fauna Issues & Statements


Response

The DEC advise that the PER does not adequately describe the region’s vegetation (page 51 of the PER). Much of the vegetation is karri forest with a mixture of jarrah and marri.

51 Noted. A detailed description of the vegetation at the site and within the region is provided in the PER Section 12.

Inadequate flora and fauna studies undertaken.

6, 12, 53

It should be noted that the plant itself is to be located primarily on the existing cleared site with only minor expansions for fuel storage and service easements (power and water). Much of the forest immediately surrounding the site where site expansion is required has been logged recently, with a substantial area heavily logged for fire hazard management purposes. Based on this, it is considered that the PER adequately addresses flora and fauna on the site. Section 12 of the PER demonstrates that no Declared Rare or Priority flora are recorded in or within 10km radius of the site and due to the disturbed nature of the site from previous uses, it is unlikely that any of the Study Area provides critical habitat for threatened or priority fauna.

There will be limited impact on flora and 49, 55, Noted, see above.


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fauna as the site is already an industrial site

More long term flora and fauna studies should be undertaken

17

Ongoing monitoring and management of impact on the State Forest surrounding the site forms part of the Environmental Management Plan.

PER does not give any detail regarding the cumulative effects of emissions on the surrounding forest areas or on fragile local flora and fauna.

6, 30

The study undertaken by CSIRO Land and Water (see summary above and full report in Appendix C) concludes that the potential effects of pollutants on the surrounding area is either negligible or acceptable.

Marron and trout and other amphibian fauna are extremely sensitive to pollutants.

4, 6, 17, 31

There is no evidence to suggest that pollutants will be of a type or level that will impact local flora and fauna. Existing biomass power plants coexist in close proximity to agriculture and aquaculture processes, with no impact on the quality of the product due to emissions. Indeed the Rocky Point Biomass project is in immediate proximity to adjoining prawn aquaculture farms without adverse impact. It should also be noted that there will be an improvement in regional air quality between emissions from the biomass plant compared to emissions from uncontrolled burning of plantation waste. The proponent will undertake an investigation and management process including representative sampling of surface dams in the locality prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly.

General requirements for the proponent to control pests such as weeds, feral animals, etc on site. In addition, contractors/persons who are applying pesticides for must be appropriately trained and hold a current pesticide License and be employed by a Registered Commercial Pest Firm. In general, pesticides must be applied in accordance with the Health (Pesticides) Regulations 1956.

46 Noted and included in the Management Plan

The trucks travelling to and from this site have the potential of spreading dieback.

19

During construction, a Dieback Hygiene Management Plan is required for any earthworks that have the potential to spread the disease on State forest (see below). This is a management commitment in the Flora and Fauna Management Plan. During operation, the fuel supply trucks will enter and exit the site via existing roads which will be sealed, and therefore the potential for the spread of dieback is negligible. It should be noted that a Timber Mill has been operating from this site for many years, with (at


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times) far greater traffic movements than are proposed for the biomass power plant. Management plans that have been implemented have effectively dealt with potential impacts such as the spread of dieback.

All work is to be compliant with the approved Hygiene Management Plan on the adjoining harvested areas and a Dieback Hygiene Management Plan should be required for any earthworks that have the potential to spread the disease on State forest

51 Noted and included in the Management Plan

Risk to cockatoos and falcons 6, 12, 17, 19 & 30

The falcon is a Schedule 4, highly mobile, fauna which is uncommon within this region and prefers areas with rocky ledges, cliffs, watercourses, open woodland or margins with cleared land. The cockatoo is a Schedule 1, highly mobile fauna, which may have from time to time used the vegetation within the Study Areas but considering the large area of State forest (which is extensively logged in some areas) surrounding the site it is not likely to comprise a critical habitat for either the cockatoo or the falcon. Based on the anticipated emissions arising from the Power Plant, it is not anticipated that there will be any negative impacts on the Cockatoo or Falcon population, should they be residing or visiting the area.

Risk to Schedule 1 fauna within a 10 km radius

6, 12, 17, 19 & 30

Eight species of Schedule 1 fauna exist within a 10 km radius of the site. With regard to the threatened and priority fauna species, in particular the Mud Minnow (Schedule 1), it is extremely unlikely that they would exist within the study area, due to extensive logging resulting in a lack of habitat. For all other highly mobile fauna species, the study area is not likely to comprise a critical habitat due to extensive logging, lack of habitat trees and the availability of State forest surrounding the site.

Area surveyed / assessed is unclear / misleading

6, 12, 17, 19 & 30

Figure 12.1 in the PER (page 109) clearly shows the mapped flora survey area, and is highlighted in shaded yellow.

Flora and Fauna survey should be referred to the Commonwealth

6, 12, 17, 19 & 30

The Department of Environment, Water, Heritage and the Arts outlines that a referral for biodiversity assessment is only required if the impact of the activity is considered significant.

A significant impact is an impact which is important, notable, or of consequence, having regard to its context or intensity. Whether or not an action is likely to have a significant impact depends upon the sensitivity, value, and quality of the environment which is impacted, and upon


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the intensity, duration, magnitude and geographic extent of the impacts. You should consider all of these factors when determining whether an action is likely to have a significant impact on the environment. The main conclusions outlined in the PER found that the study area is unlikely to provide a critical habitat for threatened or priority fauna and there is no declared rare or priority flora within the study area. In addition, there is no evidence to suggest that pollutants will be of a type or level that will impact local flora or fauna. Given the results of the flora and fauna survey, and the insignificance of the impact of the Biomass Plant, the survey was not referred to the Commonwealth. The proposed site is currently a brown field development with similar existing timber industry activities already occurring onsite, requiring minimal clearing. In addition, the plant will be operated under best management practices to ensure emission limits are complied with. Based on the above it is not anticipated that there will be an adverse impact on flora and fauna.

Requirement for regional impact assessment with regards to flora and fauna

6, 12, 17, 19 & 30

It is considered the PER adequately addresses flora and fauna at the study site. Section 12 of the PER demonstrates that no Declared Rare or Priority flora are recorded in or within a 10km radius of the site and due to the disturbed nature of the site from previous uses, it is unlikely that any of the Study Area provides critical habitat for threatened or priority fauna. There is no evidence to suggest that pollutants will be of a type or level that will impact local flora and fauna. Existing biomass power plants coexist in close proximity to agriculture and aquaculture processes, with no impact on the quality of the product due to emissions (Please refer to local and international examples within the PER, page 35 to 39). Indeed the Rocky Point Biomass project is in immediate proximity to adjoining prawn aquaculture farms without adverse impact. It should also be noted that there will be an improvement in regional air quality between emissions from the biomass plant compared to emissions from uncontrolled burning of plantation waste. The proponent will undertake an investigation and management process including representative sampling of surface dams in the locality prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly.


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From the above comments it is not considered necessary to continue with further regional impact assessment with regards to flora and fauna. Additional information regarding the above is detailed in the CSIRO report, which is provided in Appendix C.


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4.9 Indigenous and Non-Indigenous Cultural Heritage

The site is a brownfields site that has been part of the local timber mill operations for many years. It has been cleared and previously developed, and most recently used as a transport depot. Desktop searches of the heritage databases were undertaken to determine whether the proposed site was of cultural significance. These searches did not identify any sites of aboriginal or European heritage significance within the subject site. The proponents acknowledged in the PER that Aboriginal people may accord other significance to the site and that it may also be possible that sites are discovered through the construction phase of the project. The process of public advertisement of the Development Application and the PER together with public community meetings and group briefings did not result in any Aboriginal issues being raised or Aboriginal people coming forward to raise issues. That said, the proponents have engaged specialist consultants in this field to conduct appropriate enquiries with relevant Aboriginal groups (e.g. SW Boojarah) and individuals to ensure that all people are effectively consulted and engaged in the process. The Heritage and Cultural Management Plan will be further developed with input from the Aboriginal Heritage Consultant based on consultation with the relevant aboriginal people and an ethnographic and archaeological survey of the development area prior to construction. Monitoring of construction works may also be required. Very few submissions commented on the impacts the plant would have on the Indigenous & Non-Indigenous Cultural Heritage of the local area. The submission from the Department of Indigenous Affairs provided numerous comments and recommendations regarding criteria that need to be demonstrated to ensure minimal impact of the local Indigenous & Non-Indigenous Cultural Heritage. These, in addition to other comments received are detailed below. Table 4-10 Cultural Heritage Issues & Statements


Response

No evidence in the PER that any consultation about the project has taken place with relevant Aboriginal people or that sufficient background investigations and consultations have been undertaken to identify aboriginal heritage values in the area.

45, 53

During concept design and development of the plant, and the extensive community consultation undertaken to date, no Aboriginal people have been identified or made known to the proponents as part of that process. For the purposes of concept design, desktop information and site assessment has not identified any recorded sites of significance, and the construction site is already heavily disturbed.

DIA advises that further information can be obtained through: Notifying Aboriginal community and/or Native Title claimants about the proposal; Undertaking Aboriginal Heritage surveys; Recording new sites and reporting them to the DIA; and recording and reporting new information about previously registered sites.

45

An Aboriginal Heritage Consultant has been engaged by the proponents to undertake further investigation of the site prior to construction commencing. This will involve consultation with the relevant Aboriginal people, undertaking an ethnographic and archaeological survey of the site, recording and reporting any new sites, and recommending management measures for the construction and operation of the plant.

The Department of Indigenous Affairs recommends that: - any archaeological sites discovered

be reported to the Minister. It is possible that there are sites that have not yet been reported.

- if a notice under section 18 of the AHA needs to be submitted, the DIA

45 The comments of the DIA are noted and relevant revisions have been made to the Heritage and Cultural Management Plan.


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needs to be contacted prior tp commencing the application process and associated heritage surveys

- The heritage and Cultural management Section should make explicit reference to the 'Minister for Indigenous Affairs'

- The community reference group should include representation from local Aboriginal people if possible

- The Heritage and Cultural Management Section should refer to any type of Aboriginal site

- The Heritage and Cultural Management Section should refer to a policy for the Management of Aboriginal Heritage


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4.10 Solid and Liquid Waste A limited number of submissions provided comments on the solid and liquid waste associated with the proposed plant. In regards to the liquid waste, as no process water is to be discharged off site there are therefore no liquid waste issues. Some concern was raised over the transport and disposal of the ash that is to be generated from operating activities. Table 4-11 Solid and Liquid Waste Issues & Statements


Response

Ash should not be used for agricultural purposes and impacts of ash handling and disposal needs to be further explained

6, 27

Ash will only be used for agricultural purposes after it has undergone sampling to confirm it is suitable for such purposes. A sampling regime will be developed in consultation with the DEC. Where not suitable it will be disposed of in an appropriately classed landfill as per the requirements of the Landfill Waste Classification and Waste Definitions 1996 (As amended) and Department of Environmental Protection 2002, Guidelines for Acceptance of Solid Waste to Landfill.

Lack of utilisation of wastes (eg. Heat) 11

It is acknowledged that many biomass plants throughout the world use the heat by-product for things such as domestic heating and also for drying of the fuel. In this case there is no appropriate or feasible use for the waste heat.

What provisions are being made to ensure no dispersion of the ash during transport.

17, 19

Ash would be transported in an enclosed trailer by truck. Response to vehicle accidents such as truck rollovers that occur on public roads would occur through the respective emergency services (police, fire brigade, ambulance) and be addressed through the site safety and emergency response procedures. It is anticipated these site specific documents and procedures would be prepared prior to operations commencing. WA Biomass will prepare accident/incident and emergency response procedures for events that may occur within the plant area and through the operation of the plant, prior to commencement of operations.

No chemicals to be used in the process 9, This statement is correct; no chemicals are required to be used in the process.

There should be careful checking of, and accounting for, the full life cycle impacts of all forms of pollutants and wastes. In every case the aim should be zero emissions/zero waste through the use of such things as: closed cycle/closed loop technologies; state of the art cleaning/scrubbing technologies; and recycling/re-use (e.g. of all waste water).

66

Best practice processes and technologies are being applied in the design of the proposed plant to ensure full life cycle impacts of the biomass power plant including emissions are minimised, if not eliminated. There is proposed to be full recycling and reuse of water with a zero process water discharge policy.

Have the issues of dioxins in ash disposal been considered?

EPA

Research has shown that the kinetic reactions responsible for the formation of dioxins never proceed to completion. This means that, in spite of over-abundance of chlorine (and other elements that constitute building blocks for


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dioxins), most of the available material is not converted to dioxins. Dioxins are formed from surface catalysed (mainly from the presence of copper oxide) reactions (on fly-ash) and gas phase formation, with the former believed to be the major contributor to dioxin formation. Of the surface catalysed reactions, the precursor route (preformed chlorophenols/benzene react at the surface) is the primary mechanism at high temperatures, and the de novo route (eventual elemental reaction sequence) is the primary mechanism at low temperatures. After formation on the surface of fly-ash, some dioxin diffuses to the gas phase, with the rest remaining on the fly-ash. The formation of dioxins is controlled in the following ways (regardless of chlorine content): • High temperatures and long residence time

in the boiler • Fast cooling of combustion products,

minimising the time flue gases spend in 200-

450°C (eg. preheating combustion air) • Use of baghouse filters (without catalytic

media) to capture fly-ash (containing dioxin deposits)

• Presence of other trace element oxides that inhibit catalysed surface reactions on flyash

The practices will be employed in the biomass proposed power station in addition to sampling of ash in accordance with the requirements of the Landfill Waste Classification and Waste Definitions 1996 (As amended) and Department of Environmental Protection 2002, Guidelines for Acceptance of Solid Waste to Landfill.


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4.11 Hazard and Risk One submission raised concern that a professional risk assessment should be undertaken. A detailed hazard and risk assessment forms Section 17 of the PER. The methodology is based on AS/NZS 4360:2004 Risk Management and has been undertaken by an appropriately experienced professional. In response to specific concerns in relation to impacts on human health, a Health Risk Assessment (HRA) was undertaken by Toxikos Pty Ltd according to national and international guidelines and included an assessment of acute and chronic health risks that might arise from direct inhalation exposure to individual components of the biomass power plant emissions, and the mixture of chemicals in the emissions. Also incorporated into the HRA is a quantitative evaluation of cancer risks, and a preliminary evaluation of the potential healthy risks associated with exposure of emission components through the food chain (i.e. indirect exposure pathways). The HRA takes cognisance of background exposures when these were provided. Specific issues raised in relation to health impacts are addressed is Section 4.14 below. The Health Risk Assessment is provided at Appendix H(a). Other submissions raising concerns or statements regarding Hazard and Risk have been addressed under the specific environmental factor that the issue related to.

4.12 Social and Economic Numerous comments were raised in the submissions received regarding the impact that the proposed plant would have on the social environment and economy of the area. Statements provided details outlining the advantages and disadvantages associated with the development of a Biomass plant in Manjimup. The primary concern raised was that the adverse economic impacts on the local wine, agriculture and tourism industries would far outweigh the economic benefits associated with the development and operation of the proposed plant. It should be noted that based on the CSIRO Land and Water and Smart Viticulture reports, and from data presented in the PER, there is anticipated to be no adverse impacts on the aforementioned industries. Numerous statements were also received outlining the benefits associated with the proposed plant, most notable the introduction of additional jobs and skills to the area, which would have the add-on effect of creating additional economic benefits for other industries located in the area. Table 4-12 Social and Economic Issues & Statements


Response

Responding to climate change will create new business, new employment opportunities and a more sustainable economy in regional Western Australia, and diversify our industry base. Many of these opportunities will of necessity be spread across the regions in rural WA.

43 Noted

With an exodus of some 500 residents from the Manjimup Shire since 2001 the proposal offers a great opportunity for the expansion of forest-based industry by way of value-adding.

34

It is noted that the Shire of Manjimup has experienced a population decline since 2001. It is anticipated that the Biomass Power Plant will have a positive economic impact on the Shire of Manjimup, and will contribute to the local and state economy through direct and indirect employment, materials supply and general household expenditure.


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The proposal will lead to creation of jobs and skills (traineeships), diversification of industry and further investment in the area. This will improve the future of the district and allow an opportunity for sustained regional development that allows more people to settle in the area.

GS2, 4, 5, 8, 9, 18, 33, 34, 36, 37, 39, 43, 55, 58, 60

Noted

The employment created will be mostly for professionals that will be sought from outside the region.

53

A range of skills requirements will arise from the construction and operation of the proposed plant. Indeed, much of the employment generation is from the harvest, collection, and transportation of the plantation waste, an industry which currently employs many people from within the region. The proponents have been contacted by skilled people who have had to leave the region due to lack of work, and would like to return to live in the region if such an opportunity was presented. The employment created provides an opportunity for training and skills development for currently unskilled workers.

No of employees continuously changing 27

The reporting of the direct and indirect employment generation from the proposal has been consistent in the public documentation and consultation material.

Impacts on land and property values 12, 53

There is no evidence that property values in proximity of existing power plants, including biomass power plants, have declined. The Shire of Manjimup undertook a research visit to a number of existing power plants, including the Rocky Point Biomass Power Plant, to investigate potential impacts on property values and found no evidence to suggest that there has been a negative impact on the value of land adjacent to, or near, the plants.

The Manjimup Chamber of Commerce fully endorses action by the Shire of Manjimup to attract new investment and development opportunities for the region.

21 Noted

Adverse economic impacts on wine/tourism/food industry outweigh benefits associated with the plant. The number of jobs offered will not contribute as effectively to the regions economy as the businesses that the plant is likely to alienate. It is less likely that agri-investments and tourism related industries will set up in the area.

GS1, 11, 12, 13, 17, 23, 30, 31, 35, 42, 48, 50, 53, 65

There is no apparent reason to believe, based on specialist advice, that existing industries or businesses should be impacted. It is predicted that beyond the direct benefits of job creation, the security of power produced by the plant will attract investment in business and industry to the region. In point of fact, the generation of renewable energy has, elsewhere, been a positive tool for regional development.

The environmental, social and economic benefits will far outweigh any potential negatives a plant of this kind could produce.

2 Noted

Will generate power locally and allow Manjimup to show itself as clean and green. Manjimup has the opportunity to

18, 34 Noted. This is expected to attract further development and investment in the local region, as discussed above.


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lead the way by becoming the centre for renewable energy.

Will make power available for desalination plant at Binningup.

40

The power produced from the proposed Biomass plant has been contracted for purchase by Synergy.

No meaningful costings available. Need for a cost/benefit analysis to determine whether the plant is profitable

27, 53

The PER is required to respond a number of key environmental factors as determined by the EPA. A cost/benefit analysis was not a requirement, however the feasibility and sustainability of the proposal is key to the proponents willingness to pursue the project.

Will increase value of forests in the SW 36,

Noted. The removal of residues following harvesting provides both an operational and financial benefit for the plantation owners and managers. The removal of plantation residues reduces the cost and increases the area available for replanting.


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4.13 Transport The majority of submissions received, provided comments on transport issues associated with the proposed plant. Comments were varied throughout, with some statements outlining the benefits of the current transport system in place while others provided comments on inadequacies with the current transport network. Other submissions outlined possible measures that could be implemented to alleviate adverse transport impacts. The main concern raised was the adverse impact the additional heavy haulage would have on road safety and traffic along the proposed transport routes. Particular concern was raised over the existing state of the South Western Highway. Other submissions received recommended that the fuel should be transported by rail, and if this was not possible, road upgrading should be undertaken by the proponent. Other submissions received, outlined that an adequate road network is already in place, which used to cater for a greater number of heavy vehicles back in the early 1990’s. It was also noted that as the backloading of trucks from Bunbury was not accounted for in the transport modelling (the current modelling has assumed 34 truck deliveries per day), there is further potential for a reduction of up to approximately 40% in truck numbers. Key actions and commitments of the proponents include the following:

• WA Biomass and its contractors will obtain the necessary transport permits from the Shire of Manjimup for transport on local roads, and Main Roads WA, for transport on the South Western Highway and Muirs Highway.

• WA Biomass will consult with the Shire of Manjimup on any required signage, upgrading of local intersections or road pavement that is needed for safe movement of all traffic on local roads.

• WA Biomass will consult with the Shire of Manjimup and Main Roads WA on the intersection requirement of Eastbourne Road with the South Western Highway. Any required upgrade works will be undertaken to ensure safe traffic access and egress.

Table 4-13 Transport Issues & Statements


Response

Main Roads WA have no comment 15

Noted. WA Biomass will continue to consult with Main Roads WA regarding the road network, permits and management.

The site has good access to an efficient road transport network that is already in place (public & logging) that has been used to deliver millions of tonnes of logs over the last 27 years. Due to the decrease in production at Diamond Mill, the number of trucks, even with the increase to service the power plant, will be less than was using the roads in the early 1990’s. The increase in truck traffic is not a realistic concern, given the high volumes of trucks historically in the region.

GS2, GS3, 49, 39, 9, 7, 55, 8,

Noted. The proponents will work with the Shire of Manjimup and Main Roads WA to ensure safe and efficient use of the existing road transport network. The DEC controls and limits the use of DEC managed lands by heavy haulage. The fuel supply contractors currently use this road transport network, and its ongoing use will occur in consultation with the DEC.

The impact the heavy haulage will have on roads and traffic (inc. safety issues). Condition of SW Highway - most dangerous road in the state Minor roads lack centre line markings

GS1, 3, 11, 12, 16, 17, 35, 23, 42, 41, 26, 48, 50, 53, 30, 47, 31, 65, 66,

The predicted vehicle movements per day are not anticipated to result is a significant safety impact to other road users. The transport assessment identifies approved heavy haulage routes. WA Biomass and its contractors will


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and often lack suitable shoulders for passing vehicles. Trucks are adding to collapse of road edge surface making it hard for other drivers to pull off the roads.

obtain the necessary transport permits from the Shire of Manjimup for transport on local roads, and Main Roads WA, for transport on the South Western Highway and Muirs Highway. The proponents will work with the Shire of Manjimup and Main Roads WA to ensure safe and efficient use of the road transport network.

Trucks using engine compression braking down Eastbourne Road causes noise interruptions.

11, 12

As noted in the key actions and commitments above, WA Biomass will consult with the Shire of Manjimup and Main Roads WA on the intersection requirement of Eastbourne Road with the South Western Highway. Any required upgrade works will be undertaken to ensure safe traffic access and egress. This may include review of the speed limit and signage to ensure drivers limit use of compression braking (subject to MRWA consideration).

There should be a full environmental impact study on the site and the road networks used and the communities that use them.

6, 53 A transportation study has been undertaken and results are presented in Section 19 of the PER.

The DEC controls and limits the use of DEC managed lands by heavy haulage, as much of the road network is unsuitable for use by heavy haulage. All use of roads on DEC managed lands for heavy haulage is authorised on a user pays principle with due regard for public use and safety on these roads.

51

Noted. The haulage contractors proposed to transport the plantation waste have operated for some time in these plantation areas which are already established for plantation forestry and harvesting. The same networks used for transportation of the log product will be used to transport the plantation waste, with approvals to be sought as required. Further liaison with the DEC’s Warren Region regarding road availability for heavy haulage will be undertaken.

Should restrict movement of the trucks only to major and secondary roads that can be efficiently maintained and upgraded by the proponents under the direction of the Shire

53

Due to the location of many of the plantations, minor local roads must be used to access the main road network. In many cases, DEC logging roads are also used, and are managed on a user-pays basis (see above).

Backloading of trucks should be ruled out since it is not proven

GS2, 34, 9, 7, 8,

As transport contracts with existing haulage contractors will not be finalised until all relevant approvals to proceed with the Biomass power plant proposal are achieved, the opportunity to backload trucks has been noted, but has not been factored into the assessment of Greenhouse Gas Emissions or Traffic Volumes. Therefore the PER considers the worst case scenario.

Backloading of trucks will reduce traffic GS2, 34, 9, 7, 8,

Noted, see above. If backloading proves viable, the current estimation of 34 truck deliveries per day may be reduced to approximately 20 per day.

Impact of traffic on Bridgetown CBD 23, 53

Figure 19.1 shows that the majority of vehicles won’t have to pass through the Bridgetown CBD. Investigations have shown that only approximately 38% of vehicles associated with


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the Biomass plant will pass through the Bridgetown CBD. Should backloading be implemented, the increase will be negligible.

Impact on roadside vegetation 23,

The report by Smart Viticulture on the possibility of air pollution from the biomass power plant affecting neighbouring vineyards (See Appendix D) refers to only one known case where vineyards beside the New York State Expressway were known to be affected by lead emissions from motor cars. With a reduction in the use of leaded fuels this ceased to be a problem. In this case very high traffic volumes were experienced on the Expressway. The only road where significant traffic volumes are currently experienced is the South Western Highway. The expected increase in traffic volumes on the South Western Highway due to the biomass power plant is between 1.1 and 4.4%.

A significant increase in road funding is required. If the plant goes ahead the road should be upgraded to a dual carriageway from Bridgetown to the plant. If road safety is an issue then increased funding should be sought. Who will be financially responsible for road maintenance? The proponents must pay for road improvements for public safety

GS1, 9, 17, 18, 30, 53

Road maintenance and funding is an issue that is addressed through infrastructure planning by both the Shire and Main Roads WA. WA Biomass will consult with the Shire of Manjimup on any required signage, upgrading of local intersections or road pavement that is needed for safe movement of all traffic on local roads. WA Biomass will consult with the Shire of Manjimup and Main Roads WA on the intersection requirement of Eastbourne Road with the South Western Highway. Any required upgrade works will be undertaken to ensure safe traffic access and egress.

Need to look at re-opening the rail line for transportation of plantation waste.

16, 18, 48, 53, 64, 65, 66

The rail facilities at the site and in the region have not been in operation for some time and are therefore in a state of disrepair. Even if such facilities were constructed, this does not remove the need for truck transport of the biomass product on local roads, travelling from the plantation to the siding. The proponents would, however, consider the rail option for transportation of the biomass fuel, should there be a regional cost benefit approach that it supported by other industries in the area that could also benefit from the reopening of the rail line.

Using bark mulch from Mill will further reduce traffic

GS2, 9,

Noted. The opportunity to use Mill Waste in the power plant has been noted, but has not been factored into the assessment of Greenhouse Gas Emissions or Traffic Volumes. Therefore the PER considers the worst case scenario. The use of the bark mulch/timber waste would improve traffic volumes as well as local air quality as this


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waste would not be burnt in the open, as is current practice. Refer to ‘Section 4.1 Fuel Supply’ for discussion on the potential for the use of the Mill waste.

Need to confirm no truck movements on Sundays (see Tables 22-12 & 22-13).

52

The proponent confirms that fuel supply truck movements to the biomass plant will not occur on Sundays.

4.14 Health Risk Numerous concerns were raised in the submissions received regarding the potential impacts plant emissions would have on human health including from the Department of Health who requested specific additional advice be provided. Although the Department of Health agreed that a full health risk assessment was not necessary, the proponents committed to undertaking such an assessment. The Health Risk Assessment (HRA) was undertaken by Toxikos Pty Ltd according to national and international guidelines and included an assessment of acute and chronic health risks that might arise from direct inhalation exposure to individual components of the biomass power plant emissions, and the mixture of chemicals in the emissions. Also incorporated into the HRA is a quantitative evaluation of cancer risks, and a preliminary evaluation of the potential healthy risks associated with exposure of emission components through the food chain (i.e. indirect exposure pathways). The HRA takes cognisance of background exposures when these were provided. The Health Risk Assessment is provided at Appendix H(a). In summary the conclusions of the Health Risk Assessment are as follows:

• It was concluded direct health risks from exposure to the emissions from the power station is unlikely, however there is uncertainty associated with the conclusion because the accuracy of the estimates, and/or by how much actual emissions may have been overestimated, is unknown. In these respects the HRA is conservative, i.e. err on the side of safety.

• In the cumulative assessment of biomass plant emissions plus other sources of emission

components, the acute health risks are dominated by background airborne particulates, approximately 90% of the risk is due to background particulate matter (PM). Using 98th percentile ground level concentrations for particulates in biomass plant emissions and local background concentrations, the results are at or about the target for declaring it would be very unlikely health effects would occur.

• Calculated cancer risks (~0.3 x 10-5) are within the band of acceptability used by many

Australian and overseas jurisdictions, which in conjunction with the small population that may potentially be exposed, indicates it is unlikely a person will develop cancer as a result of exposures to the emissions.

• Dioxins, PAH and the metals were assessed for potential health risks associated with

exposure of emission components through the food chain using screening techniques developed by Toxikos. These techniques are conservative and are applied to initially determine if health effects from the secondary food exposure pathways are likely to be of concern, and hence if detailed evaluation of these exposures is necessary.

• On the basis that (a) the predicted air concentrations of dioxins are significantly less than in

Europe, Japan or what has been measured in the air elsewhere in Australia, and (b) calculated total intake (background, direct inhalation and via food) is much less than the tolerable intake set by health authorities, it was concluded there is negligible health risk associated with dioxin emissions from the proposed power station.


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• It was similarly concluded that polyaromatic hydrocarbons (PAH) and the metals cadmium and mercury emitted by the proposed power station present negligible health risks via exposure through the food chain.

The Department of Health has reviewed the Health Risk Assessment prepared by Toxikos and has advised that the report largely addresses the Departmental and the community concerns on the health impacts of emissions from the plant (refer correspondence in Appendix H(b)). The Department felt that the shortcomings in the data, and reservations surrounding the predicted levels of PM10 and impact of PAHs, can be overcome with a commitment from the proponent to monitor and report on PM10 and rainwater tank levels of PAH. The Department also requested a commitment to the proposed sulphur dioxide controls and metal ash analysis. These commitments have been made in the Air and Water Quality management plans. The Department noted the conclusion in the report that dioxins, PAHs and heavy metals will not accumulate to an extent where food chain contamination is likely. Overall, it is considered that the Department’s concerns have been addressed by the proponent’s willingness to commit to these measures. A list of the issues and statements received concerning health impacts are presented below. Table 4-14 Health Risk Issues & Statements


Response

The Dept of Health stated that a full health risk assessment in line with the enHealth document was not necessary since other criteria pollutants modelled appeared to be well within AQ guidelines.

46

Noted. Despite a less rigorous Health Risk Assessment (HRA) expected by the Dept of Health, the proponents committed to undertaking this assessment to ensure that any likely health risk was adequately assessed. The proponent commissioned Toxikos to carry out an independent Health Risk Assessment. Refer to the report in Appendix H(a). .

Potential increase in health risks from airborne contaminants (particulates and gases) emitted by the power plant.

GS1, 3, 6, 10, 12, 13, 19, 22, 24, 26, 28, 31, 35, 42, 48, 50, 65, 53,

The HRA considered health risk associated with a range of pollutants including the criteria pollutants, as well as “toxic” pollutants such as Dioxins, PAH’s etc. The HRA concludes that, based on the 98th percentile cumulative concentrations of power station emissions and background air quality, it would be very unlikely health effects would occur.

Assess the accuracy of the statements and make comment on the content of data provided regarding: "Emission of endocrine disruptors from biomass and diesel fuel consumption".

25

Natural hormones in the human body are responsible for processes such as reproduction, development and behaviour. Together, these hormones make up the endocrine system, and chemicals that interfere with or mimic their action are known as endocrine disruptors. Potential compound that of this type that may be released by the proposed power station include: dioxins, polychlorinated biphenyls (PCBs), polyaromatic hydrocarbons (PAHs), phthalates and phenols. The HRA has considered these compounds and concluded that “there is negligible health risks associated with dioxin emissions from the proposed power station … It was similarly concluded that PAH and the metals Cadmium and Mercury emitted by the proposed power station present negligible health risk … ”.

The PER does not adequately address public health issues. There has not been

41, 31, 54 Please see above and refer to the Health Risk Assessment in Appendix H(a) . Following


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sufficient evaluation of the health risk. The review of the AQ Assessment undertaken by the Dept of Health should be provided to the public.

consultation with the Department of Health (DoH), a rigorous health risk assessment was commissioned (extending beyond the expectation of the Dept of Health). The HRA concludes that, based on the 98th percentile cumulative concentrations of power station emissions and background air quality, it would be very unlikely health effects would occur. The DoH has reviewed the HRA and its response is included in Appendix H(b).

Impacts on public health may not be known until plant has been in operation for a considerable length of time. Biomass plants not around long enough to assess health & env impacts.

10, 50

The publication “Lessons Learned from Biomass Power Stations” lists power stations in operation in agricultural regions of North America, since 1979. These plants have been in operation from 30 years without impacting health effect (other than reducing emissions from agricultural burn-offs). The revised air quality assessment lists numerous power stations operating in agricultural (including viticultural) regions throughout Europe and North America without affecting the health of those living nearby.

Bag filters are proposed but they only filter out particles to PM10, smaller molecules are the major health concerns (PM2.5) and noxious gases.

30, 53

The reduction rate associated with the use of a fabric filter is considered to be 99.95 % or higher and is, therefore, considered by the IPPC as the first Best Available Technology choice for biomass fuelled boilers. These filters also minimise the emission of heavy metals, since they have the tendency to accumulate preferentially on the finer particulates. Gases do pass through these filters, however the concentration of these gases is controlled by an efficient combustion process using a bubbling fluidised bed boiler. Various emissions of solid and gaseous compounds have been estimated and used in the HRA, which has not warned of any hazards to human health (independently or in combination).

Site not suitable due to very high risks to health, food chain & environment

6

CSIRO Land and Water group undertook a detailed assessment of the likely effects of pollutants on agriculture, including absorption of pollutants via air and soil pathways (see Appendix C). The assessment considered a broad range of compounds and trace elements that could be emitted from the power station. CSIRO concluded that risks on agriculture were acceptable, but that monitoring was required.

4.15 Monitoring and Management Various comments and statements were received regarding the monitoring and management strategies proposed for the plant. The primary concern raised was that insufficient baseline studies and information was presented to determine existing environmental conditions of the site and surrounding environment. Concerns were also raised regarding the frequency of future monitoring proposed and the number of parameters being monitored. These concerns are addressed below, in addition to other issues and statements raised regarding monitoring and management procedures associated with the proposed project.


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Table 4-15 Monitoring and Management Issues & Statements


Response

Support installation of monitoring programs within the vicinity of the site.

18 Noted

Need adequate management and monitoring programs

53

Monitoring and management measures to be implemented are outlined in the various Environmental management Plans contained in Section 22 of the PER. Based on submissions and advice from decision making authorities, revised management plans are outlined in Section 3.2 of this document.

The insufficient base line studies. 6, 16, 30, 53

The proponent is committed to a baseline monitoring program for ambient air pollutant concentrations prior to operation, together with establishing a permanent meteorological monitor at a fixed location. Baseline monitoring will be carried out at a minimum of 5 sensitive receptors around the plant. Monitoring will be carried out for a minimum period of 12 months prior to plant operation. Monitoring will continue over the life of the plant.

Requirements for monitoring (PAH, particulate levels)

6

Monitoring will include but not be limited to criteria pollutants (NO2, SO2, CO, O3, Pb, PM10, PM2.5 etc) and air toxic pollutants (PAH, PCDD/F, Trace Elements). Ambient air monitoring at sensitive receptors around the plant, together with real-time in-stack monitoring will be carried out. Monitoring methods will comply with Australian Standards (or International Standards if Australian Standards are not developed). Refer to the further discussion on monitoring frequency and duration in response to this issue below.

Requirements for additional studies (Food Safety Certificate not compromised, Crops grown in 10km area, full water requirement review, water supply).

6

The PER addresses the key environmental factors as determined by the EPA. Additional studies have been done and are provided as attachments to this document to address issues raised through the public review.

PER does not contain a monitoring or management program to assess the impact on rainwater collection in the vicinity.

41

The proponent will undertake an investigation and management process including representative sampling of drinking water supplies in the locality based on Australian Drinking Water Guidelines 2004 prior to and during plant operations. If there is any increase in pollutant levels due to the operation of the power plant, the proponents would review the plant filtration and control processes accordingly.

Monitoring should be monthly and not six monthly

17

Monitoring will comprise: − Ambient air quality : This will involve

continuously monitoring criteria pollutants over the life of the plant at sensitive receptors around the plant (minimum of 3). Continuous (hourly) monitoring of criteria pollutants will occur for 12 months prior to


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plant operation, and thereafter for the life of the plant. Air toxics will be monitored on a monthly basis for the first year of operation, and thereafter every 6 months.

− In-stack Monitoring : Real-time continuous in-stack monitoring will be carried out to control plant operations, ensure compliance with emissions guarantees, and for external auditing for quality assurance.

− Meteorological Monitoring: A permanent automatic weather station will be installed at the site to log weather conditions on an hourly basis prior to construction, and throughout the operational life of the plant.

Results of monitoring will be used to verify the air dispersion model.

Request that 12 - 24 month climatic and environmental studies be carried out in the Diamond area as well as in major towns of Manjimup and Pemberton.

31

Baseline monitoring of ambient air pollutant concentrations prior to operation, together with meteorological monitoring at a fixed location. Baseline monitoring will be carried out at a minimum of 3 sensitive receptors around the plant. Monitoring will be carried out for a minimum period of 12 months prior to plant operation and will continue over the life of the plant.

Recommend that EPA conduct leaf analysis on leaf samples close to existing plants to determine emission particle levels

14

The study undertaken by CSIRO Land and Water (see Appendix C) finds that to date, no jurisdiction has considered the hazard posed by particulates to the environment as significant enough to warrant development of air quality or soil quality “predicted no-effect Concentrations” (PNECs) to protect the environment. The predicted direct toxicity hazards from dioxin and furan emissions to plants and agricultural crops are predicted to be acceptable. Given the predicted low levels of emissions from the biomass power plant compared to existing background conditions, leaf analysis is not considered warranted. However, monitoring of emissions will be undertaken to ensure predicted emissions are in line with actual emissions, and that actual emissions are within regulatory limits.

Recommend that EPA test soils and water sources close to existing plants.

14

Whilst no biomass power plants of this type exist in WA over which the EPA has jurisdiction, plants that exist in eastern Australia are regulated by the State or Territory environmental authority and monitored under a regular regime of air, noise and water quality testing.

DOH request that the proponent, in addition to routine heavy metal analysis also commit to an appropriate management strategy for handling potential heavy metal contamination in

46

Various fuel samples have had ash analysis undertaken. The proponents have committed to a sampling and management strategy for both furnace and fly ash. We commit to including heavy metals analysis in the sampling program.


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ash

Fire management issues require further discussion and clarification with the DEC.

51

Noted. The required consultation will take place in the development of the detailed Fire Management Plan prior to construction commencing. It is also understood that general conditions relating to fire management are proposed to be included in the CALM Act Lease (see below)

General conditions relating to on-site disturbance, management of fire risk, weeds and soil protection are proposed to be included in a CALM Act lease, subject to CALM Regulation amendments.

51 Noted

DEC requests that the overall training package goes beyond the power station site, and includes information regarding the locally publicly owned conservation and forest lands (national parks, nature reserves and State forest) and that staff are aware of requirements for appropriate behaviour in these areas.

51 Noted and agreed. This will be incorporated in the Environmental Management Plan.

Commission a thorough, independent assessment of air pollution and health impacts associated with the proposed plant.

26

In response to specific concerns in relation to impacts on human health, a Health Risk Assessment (HRA) was undertaken by Toxikos Pty Ltd according to national and international guidelines and included an assessment of acute and chronic health risks that might arise from direct inhalation exposure to individual components of the biomass power plant emissions, and the mixture of chemicals in the emissions. Also incorporated into the HRA is a quantitative evaluation of cancer risks, and a preliminary evaluation of the potential healthy risks associated with exposure of emission components through the food chain (i.e. indirect exposure pathways). The HRA takes cognisance of background exposures when these were provided. Specific issues raised in relation to health impacts are addressed is Section 4.14 below. The Health Risk Assessment is provided at Appendix H.

Approval should be conditional on a one billion dollar trust account as a bond against any future claims against the company. Polluter Pays principle should apply. No compensation values are stated.

17, 30

WA Biomass will be bound to comply with lease, licence and operational requirements under legislation, and should non compliance occur then there are a range of penalties available to regulators.


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4.16 Miscellaneous A number of submissions received also raised other issues and statements that were separate from the topics outlined above. These issues and statements are addressed below. Table 4-16 Miscellaneous Issues & Statements


Response

The Conservation Council of WA fully supports renewable energy initiatives so long as they are appropriately sited and have no negative impacts.

54 Noted

An independent, scientifically based environmental assessment should be conducted with all costs to be dealt with by the proponent.

26, 53

Connell Wagner are independent of the proponent and have conducted a full environmental impact assessment of the proposal in accordance with PER guidelines based on an EPA approved Scoping document. In addition, Connell Wagner has commissioned specialist independent technical reports on specific issues of particular concern raised in submissions. These reports are provided in full as Appendices to this Response to Submissions report.

Why other alternatives have not been considered (wind, solar or existing coal plant)?

10, 12, 24, 31, 53

Section 2.9 of the PER demonstrates why this type of renewable energy is the most suitable for the area.

The oldest biomass plant in Australia is only 7 years old and this is not long enough to evaluate the impacts.

10

Renewable power production using agricultural and wood waste has been undertaken since the 1950’s in Australia (Australian Business Council for Sustainable Energy, Renewable Power Plant Register 2006, Power plants operating as at 31 Dec 2005). It is therefore considered a tried and tested form of power generation in Australia and also overseas.

The use of biomass to generate power has been widely accepted in other countries as a green alternative for many years without any ill effect

57 Noted. See above.

The Developer send all residents within the Manjimup Shire information regarding the adverse health effects and possible negative impacts on residents and the environment.

6

The PER document contains an objective and thorough assessment of the key environmental factors. In response to concerns by the community regarding specific health and environmental impacts, additional studies have been undertaken by CSIRO Land and Water (Impacts on Soil and Agriculture, see Appendix C) and Toxikos (Health Risk Assessment, see Appendix H) which are provided as Appendices to this report and available to all residents within the Manjimup Shire.

Lack of consultation 28

The proponents believe that sufficient public consultation has been undertaken in order to identify the issues and concerns of the community and stakeholders. These concerns are addressed through this Response to Submissions and in the additional studies undertaken in order for the EPA to undertake its assessment of the proposal.


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Section 5 of this report relates to the Stakeholder Consultation undertaken for the proposal to date.

Issues with Biomass Power Plants cited in PER (Rocky point & Redbank2)

28

There is no reference in the PER to the Redbank Power Plant. Information relating to the Rocky Point Biomass Power Plant was used for comparison of biomass power generation technology.

An incorrect address for the EPA shows the Developers inability to produce a professional document.

6

The references to the EPA and its contact details were written in accordance with the template provided by the EPA. The proponents are not aware of any inaccuracies with the address.

Misrepresentation that Pemberton Visitors Centre has given approval to the proposed biomass plant

19, 41, 31,

Connell Wagner received correspondence on 4 February 2008 from the Pemberton Visitor Centre bringing to notice that a statement made in the PER was false. On page 213, para. 3, it states “Manjimup and Pemberton Tourist Centre: Have indicated support for the project”. This statement was made based on discussions between the project’s local community liaison and the managers/representatives of the Tourist and Visitor Centres throughout late 2007 and early 2008. The Pemberton Tourist Centre has advised that the Board of Management has not yet had the opportunity to discuss the matter. As the statement included in the document was based on feedback from an individual, and not the Board of Management, we therefore retract this statement. The Pemberton Visitor Centre stated its understanding that the Manjimup Visitors Centre was in a similar position, however we have written correspondence from the Manjimup Visitors Centre indicating its endorsement of any action by the Shire of Manjimup to attract new investment and development opportunities to the region.

The current PER is flawed on the basis that it contains data which is inaccurate and not specifically relevant to the proposed Manjimup Biomass plant. Request assurance that the proponent has not used the same data as that used in the Bridgetown proposal

31, 41 The data used is specific to both the proposed technology and the proposed site at Diamond Mill.

Bridgetown mentioned instead of Manjimup in Executive Summary

6, 17

Noted. This was a typographical error. It in no way demonstrates that the PER assessment is not specific to both the proposed technology and the proposed site at Diamond Mill.

Shire of Wanneroo have approved similar biomass plant and in a much more populated area

34, It is noted that a 45MW biomass power plant is proposed for the Neerabup Industrial Area.

Similar plants operating in larger 33, This is noted and is an important consideration.


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populated areas and food production areas

While a biomass power plant of this size does not currently exist in Western Australia, the proponent and its consultants have extensive experience and knowledge in the design and operation of biomass power plants.

Require further information regarding the extent and nature of impacts of the proposed source and transport of boiler bed sand feed.

51

Building construction sand is required and local building materials suppliers have been contacted with regard to its supply. Local suppliers have confirmed that there is no difficulty in meeting this requirement from existing sources. The sand would be transported to the site by truck along the same access routes as the fuel supply trucks and other service vehicles.

The Developer allows at least 18-24 months to collect local data and complete necessary scientific studies.

6

The proponents consider that sufficient data has been collected to complete necessary scientific studies. A program of baseline monitoring would commence on approval of the EPA as part of various Environmental Management Plans.

The construction period requires additional time to prevent work being completed during nights or weekends.

6 The estimated period for construction reported in the PER takes into account construction restrictions which are detailed in the PER Section 14.2.2 Construction Noise.

The five principles (precautionary, biodiversity etc) have not been addressed

19, 31, 41, 48 The five principles (Precautionary, biodiversity etc) have been addressed within the PER. Table 7.1 (page 55) outlines the principle, the relevance of each principle and if the principle has been considered.

The proposal does not meet EPA objectives or mission of the Manjimup Shire

27 The Manjimup Council's Mission is:“To serve our community and meet its needs and our statutory responsibilities in a planned and sustainable manner. In addition, the vision for the Shire of Manjimup is for a strong and united community, a diverse and growing economy, a vibrant and healthy lifestyle and our rural and forest character to be preserved.”

The EPA’s objectives are to: “Protect the environment and to prevent, control and abate pollution.” The EPA objectives are met for the following reasons: • The proposed Biomass Power Plant will be

fuelled by a renewable energy resource (plantation waste), which is currently disposed of through open air, on-site burning, resulting in uncontrolled levels of particulate emissions across the region. When consumed in the Biomass Power Plant, the emissions are reduced in a highly controlled and filtered environment.

• The plant will contribute to an overall reduction in greenhouse gas emissions; and

• The Plant also ensures emissions are below


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the prescribed guideline levels, which has been verified by independent consultants, including Katestone, CSIRO and Smart Viticulture, as attached in Appendix C, D and E.

The Manjimup mission and objectives are met for the following reasons: • The environmental benefits together with

effective environmental impact management, as described above for the EPA.

• Total capital expenditure of Biomass Plant expected to be approximately $110 million.

• The supply and processing of the biomass fuel will also provide revenue to the local contractors and haulage companies (estimated cost of $ 2.7 to 3 million for biomass processing and $7 million for equipment hire).

• Positive economic impacts will contribute to the local, international and state economy through direct and indirect employment, materials supply and general household expenditure.

• Maintenance expenditure on the plant will be in the order of $2.5 million per annum for 25 years, also contributing to the local and state economy.

• Creation of approximately 350 short term and 100 long term jobs, both directly and indirectly, in the region.

• Provides a more reliable power supply for the region for lifestyle and economic growth.

• Reduction in fire hazard by managing plantation waste

• Preserves and enhances the existing character of the region by providing a sustainable plantation based timber industry.

• The PER document illustrates that there are potential environmental impacts from the Plant, however through the implementation of the environmental management strategies, these impacts are manageable.

Lease of land for proposal and partnership arrangement between WA Biomass and Diamond Mill should be public knowledge

35 The partnership arrangement between WA Biomass and Diamond Mill has been referred to in the PER, specifically paragraph 4 in the Executive Summary and paragraph 2 in the Introduction. The PER is a publicly available document.

Insufficient public meetings. No proper advertisements of public meetings

6, 19, 27, 28, 29, 31 and 41

The proponents believe that sufficient public meetings were held. A public information booth was setup at the Cherry Festival on 8th Dec 2007 (advertised in the Manjimup Bridgetown Times, 5/12/07). The information booth was manned by four representatives of the proponent.


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A Public Meeting was held on 30th Jan 2008 in the Manjimup Town Hall (Advertised on 23/1/08 and 30/1/08). WA Biomass representatives provided a presentation of information from the PER document and then took questions. A Local Resident and Stakeholder Meeting was held in Middlesex Hall on the 13th Feb 2008 to inform attendees of the PER and answer queries. Additional meetings and consultations were also held and details regarding these are presented in Section 5 of this document.

Lack of PER availability 6, 19, 27, 28, 29, 31 and 41

The availability of the PER documents was advertised in the West Australian in accordance with EPA requirements. It was also advertised in the Manjimup Bridgetown Times in the Public Notices section, and then in full page advertisements on a weekly basis throughout the entire public comment period. Copies of the document were made available on the Connell Wagner website, from the Connell Wagner office, and hard copies of the documents were placed at a number of locations in Manjimup and Pemberton throughout the public comment period. Additional copies were provided to community members and other stakeholders immediately upon request.

No consultation with residents of Pemberton, Quinninup, and Northcliffe

6, 19, 27, 28, 29, 31 and 41

Opportunities existed for residents from Pemberton, Quinninup and Northcliffe to attend public meetings. Details of public meetings were published in local newspapers. WA Biomass representatives provided a presentation of information from the PER document to the Pemberton Wine Region Association on January 31st 2008, and then took questions. The contact details of project representatives were provided in full page advertisements in the weekly local newspaper throughout the advertising period offering residents throughout the region the opportunity to request a meeting or further information. All requests were responded to promptly.

Intention to upgrade to 120MW for higher viability.

24, 47, 48 There is no intention for future expansion as the plant is designed for a fuel capacity of 380,000 tonnes/annum based on the fuel specifications proposed in the PER. The proponent is not seeking approval for expansion or upgrade.

PER to provide impacts and management for future intentions / expansions.

24, 47, 48 There are no future intentions or expansions proposed.

Proponent actually intends to burn 660,000 tonnes/annum of woodwaste.

24, 47, 48 The Plant is designed for a fuel capacity of 380,000 tonnes/annum based on fuel specifications, as outlined in the PER.


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5. Stakeholder Consultation Summary

WA Biomass is committed to involving the community wherever possible in the decision-making process. Therefore an extensive community involvement program has been conducted, the main focus of which has been to engage stakeholders who may be directly affected by the project to ensure that key community issues are appropriately addressed during the environmental impact assessment. Comments were made in submissions to the PER criticising the lack of information provided to the community by the proponent, and alleging that the proponent had provided misleading information. WA Biomass and Connell Wagner have been assisted in stakeholder engagement by a local community liaison who has directly engaged with a number of local community business and government stakeholders to understand any concerns or issues with the proposal. This involved a large number of individual discussions with farmers, neighbours to the plant, community organisations and interest groups. In addition, representatives of the proponents and Connell Wagner attended critical meetings with interest groups, community organisations and industry bodies. The proponents have also regularly briefed the local media on issues and concerns raised by the local community and published data responding to community concerns. A questionnaire was published in the local paper (Manjimup Bridgetown Times, 20/2/08) by a local community member asking various questions relating to the provision and availability of information. Submission number 19 provided a summary of a number of these surveys including statistics by percentage of responses. However the total number (e.g. sample representation) was not stated and it was therefore difficult to determine the validity of the submission. A further 68 completed surveys were also submitted to the EPA. All of these submissions indicated that the respondent felt that sufficient information had been provided by the proponent, and the information was readily available. The following information is in chronological order, commencing from referral of the proposal for a biomass power plant at the Diamond Mill site in October 2007. Prior to this referral it should be noted that significant consultation was undertaken with the Department for Environment and Conservation (DEC), WA Plantation Resources (operators of Diamond Mill) and the Shire of Manjimup to determine the suitability of the proposed site against other locations that were being considered in the site selection assessment. Date Consultation Type Outcomes/Comments

Website: http://www.conwag.com/project_feedback/Biomass_power_generation_plant.asp. The website provides background information on the proposal and the associated planning and environmental processes.

The website has been available throughout the entire project and has been updated regularly to keep the community informed and to provide consultation documents to the public.

8 October 2007

Preliminary briefing involving the Shire, WA Biomass and the EPA SU to introduce the site.

18 October 2007

Referral of the Proposal to the EPA The level of assessment was set at Public Environmental Review (PER) with a four week public review period. The 14 day appeal period on this decision closed on 12 November 2007 and no appeals were received.

26 October 2007

Introductory Information Brochure provided to key stakeholders, Shire of

A number of landowners, residents and stakeholders contacted Connell Wagner in


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Date Consultation Type Outcomes/Comments

Manjimup (front counter) and neighbouring landowners.

response to the brochure requesting information on the process and highlighting concerns that they wanted to see addressed in the Environmental assessment. The outcomes and details of which are summarised below.

31 October 2007

Shire of Manjimup: briefing on the preliminary findings provided to the Shire’s technical staff

8 November 2007

Shire of Manjimup: briefing on the preliminary findings provided to the Shire Councillors.

Specific information has been provided to the Shire in response to queries on an ongoing basis in preparation for the submission of the Development Application.

29 November 2007

EPA Approval of Scoping Document The approved Scoping Document provided the methodology for the assessments undertaken for the Public Environmental Review.

8 December 2007

Cherry Festival Consultation and Public Display (advertised in the Manjimup Bridgetown Times, 5/12/07). The information booth was manned by four representatives of the proponent. The information provided was in the form of two A0 sized posters detailing engineering, biomass fuel, and proposed site location details of the project, together with replicated hand-out information brochures. Samples of the biomass fuel were also on display for the public.

Approximately 85 local residents met with WA Biomass representatives during the day. Representatives were asked various questions on issues relating to the project with approximately 98% of the residents consulted on this day being supportive of the project. Several community members endorsed the relocation from Bridgetown to Manjimup.

12 December 2007

The Development Application (DA) was submitted on 12 December 2007 and was advertised for public comment by the Shire for a period of 8 weeks.

The DA Comment period was set to close on 1 February 2008. This period was extended by the Shire of Manjimup for two weeks in response to requests from the community for an extension.

24 January 2008

EPA Advised that the Public Environmental Review document was approved for release. The Public Review period was set to start on 28 January 2008 and close on 26 February 2008.

The availability of the PER documents was advertised in the West Australian in accordance with EPA requirements. It was also advertised in the Manjimup Bridgetown Times in the Public Notices section, and then in full page advertisements on a weekly basis throughout the entire public comment period. Copies of the document were made available on the Connell Wagner website, from the Connell Wagner office, and hard copies of the documents were placed at a number of locations in Manjimup and Pemberton throughout the public comment period. Additional copies were provided immediately upon request.

30 January 2008

Public Meeting held in the Manjimup Town Hall (Advertised on 23/1/08 and 30/1/08). WA Biomass representatives provided a presentation of information

The public meeting was attended by local residents and stakeholders (est. 200 people). The questions asked and responses given were recorded and are covered in Section 4.


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Date Consultation Type Outcomes/Comments

from the PER document and then took questions.

31 January 2008

Pemberton Wine Region Association meeting

WA Biomass representative provided a presentation of information from the PER document and then took questions. The President of the Association undertook to provide written questions following the meeting to which the proponents could respond. No further correspondence was received.

6 February 2008

Manjimup Chamber of Commerce meeting

WA Biomass representative provided a presentation of information from the PER document and then took questions. Following the meeting the Chamber moved to write a submission of support for the proposal.

7 February 2008

Economic Development Advisory Committee meeting - community based Committee to develop a plan for the economic future of the community. This committee is made up from a blend of business leaders and Councillors

WA Biomass representative provided a presentation of information from the PER document and then took questions.

13 February 2008

Local Resident and Stakeholder Meeting – Middlesex Hall

The public meeting was attended by local residents and stakeholders (est. 50 people). WA Biomass representatives provided a presentation of information from the PER document and then took questions. The questions asked and responses given were recorded and are covered in Section 4.

20 February 2008

Presentation to Trees South West (a Regional Plantation Committee committed to the promotion and development of Farm Forestry in the South West Region, with representation from Farmers, the Timber Industry(from plantation establishment through to processing), Local & State Government and the Community.)

WA Biomass representatives provided a presentation of information from the PER document and then took questions followed by a visit to the proposed site.


Appendix A Fifth Estate Report


Appendix B Correspondence from Biomass Fuel Suppliers


Appendix C CSIRO Land and Water Report


Appendix D Smart Viticulture Report


Appendix E (a) Air Quality Assessment

(b) Correspondence from Katestone Environmental


Appendix F Noise contours


Appendix G (a) Stormwater Modelling and Proposed Management Options

(b) Correspondence from the Department of Water


Appendix H (a) Health Risk Assessment, Toxikos Pty Ltd

(b) Correspondence from the Department of Health

Documents

Updated WA Biomass Response to Submissions FINAL 21 May …€¦ · Title: Updated WA Biomass_Response to Submissions FINAL 21 May 2008 Author: graslr Subject: Manjimup Biomass Power